ERT response to EFRAG’s public call for input on sustainability reporting

This paper is the European Round Table for Industry’s (ERT) formal response to EFRAG’s 2025 consultation on the revision of the European Sustainability Reporting Standards (ESRS) Set 1, particularly focusing on ESRS S1. As the cross-sectoral, high level forum for leaders of major European industrial and technology companies, ERT highlights the considerable implementation challenges encountered in aligning with the ESRS, despite longstanding experience in sustainability reporting through frameworks such as GR (the Global Reporting Initiative).

The response contextualises the ESRS within the broader objectives of the Corporate Sustainability Reporting Directive (CSRD), supporting its ambition for high-quality and transparent sustainability disclosures. However, we outline some of the excessive complexity, prescriptive data requirements, and lack of clear guidance that companies led by Members of ERT have encountered  — challenges that disproportionately affect multinational enterprises with diverse operations and global supply chains.

ERT advocates for a streamlined, materiality-driven reporting regime that prioritises relevance and decision-usefulness. Key proposals include simplifying the double materiality assessment, allowing more flexibility in narrative and quantitative disclosures, and aligning terminology and metrics with international standards like IFRS and GRI. The paper also calls for greater legal clarity, reduced duplication, and protection of commercially sensitive forward-looking information. Overall, ERT’s position aims to reduce compliance burdens while preserving the integrity and comparability of sustainability reporting in Europe.