29 August, 2025

It has been a cruel summer for EU sustainability regulation. Last month the European Commission adopted a “quick fix” delegated act to ease certain CSRD disclosures and EFRAG released revised ESRS drafts for public consultation. For companies preparing reports this year the pace of change has been striking, raising the question of whether the omnibus simplification agenda has delivered simplification or added another layer of uncertainty. 

Under the “quick fix”, wave 1 companies can now omit certain disclosures (biodiversity disclosures (E4), reporting on value chain workers, affected communities and end users (S2–S4), as well as several datapoints within S1 on their own workforce) for the next couple of years. While these adjustments reduce the imminent reporting burden, they have arrived at a time when many companies are mere days or weeks away from publishing their first reports.  

At the same time, EFRAG opened a 60-day consultation on revised ESRS exposure drafts. The new version is built around six so-called ‘levers of simplification’, from making the double materiality assessment more pragmatic and trimming datapoints, to streamlining how policies and targets are reported upon, drawing a sharper line between what is mandatory and what is guidance, easing expectations on value chain and other high-cost disclosures, and moving closer to ISSB standards. Together, these levers create a framework that looks leaner, not only when set against the original ESRS, but even compared with the voluntary frameworks that originally inspired it, such as GRI, TCFD and TNFD. 

Yet in stripping back the rules, the heart and soul of the directive risk being lost. CSRD’s original remit was to drive change on less visible or regulated areas, such as biodiversity, value chain workers and affected communities. These are precisely the disclosures now pushed into the background. The adjustments may ease the burden but also raise questions about consistency and comparability. For early adopters, the exemptions risk looking like a late shift in the rules. Others may welcome the breathing room, but a two- or three-year reprieve means the deadlines will still arrive, just as the original CSRD requirements did after years of notice. 

The consultation on the revised standards is open until September 29th and offers an opportunity to weigh in on how the balance between usability and ambition should be struck. At Good Business, we will be submitting feedback and would welcome perspectives from clients and peers. If you are considering a response and would prefer not to do it alone or would like to talk through what this means for you, please reach out.  

By Mariana Garcia