ERT recommendations and concrete suggestions on the revision of the European Sustainability Reporting Standards (ESRS)

Brussels, 26 February 2026: The European Round Table for Industry (ERT) strongly supports the overall process to revise the European Sustainability Reporting Standards (ESRS) Set 1 to significantly reduce the reporting burden on European companies while considering the needs of relevant stakeholders. However, despite some progress, we believe that the current proposals for simplification as outlined in the technical advice published by EFRAG on 3 December are insufficient to significantly reduce the reporting burden for companies in line with the promises of the Commission’s simplification agenda.

This new ERT paper summarises our key concerns relating to EFRAG’s technical advice and provides constructive and concrete solutions to improve the standards in the final Delegated Act. The key concerns outlined in the annex are underpinned by guiding principles that we encourage the European Commission to consider as it develops the Exposure Draft:

1.  The ESRS revision should not include any new mandatory disclosure requirements or datapoints. Similarly, no datapoints that are currently voluntary should be made mandatory.
2. Completely delete the mandatory disclosure requirements on current and anticipated financial effects due to a lack of mature and established methodologies to assess them.
3. Remove all datapoints on sub-topics that are not sufficiently mature to be included in the current ESRS Set 1 (e.g. disclosure on secondary microplastics).
4. The ESRS should not mandate any specific behavioural requirements (e.g. the reference to a reduction of GHG emissions of approximately 90–95% in the Net-zero target definition). They should only focus on disclosure and transparency requirements.
5. Changing terms and underlying concepts should lead to a significant simplification and clarification of the ESRS, and not the opposite.
6. The materiality assessment should be further simplified, more principles-based and less prescriptive, providing more flexibility to preparers.