DRSC Comment Letter on EFRAG’s Draft XBRL Taxonomy

On November 11, 2026, the DRSC submitted a comment letter to EFRAG on the draft of an XBRL taxonomy for the revised ESRS (Delegated Regulation (EU) 2026/1563). In addition to the consultation questions, the DRSC also addressed general issues related to digital sustainability reporting.

In its comment letter, the DRSC fundamentally questions the benefits of iXBRL tagging in light of current technical developments in artificial intelligence. Any new proposal for digital sustainability reporting should be subject to a comprehensive cost-benefit analysis, combined with a field test. If this analysis concludes that the additional effort required for tagging by preparers of the information is justified in light of the added value for users of the information, preparers should be granted appropriate transition periods to adapt to the new provisions. In addition, mandatory, highly granular tagging of information should be avoided whenever possible, as it is very time-consuming and prone to errors.

Background:

Undertakings required to prepare sustainability reports must prepare their (consolidated) management report in the uniform European Single Electronic Format (ESEF) set forth in Article 3 of the ESEF Regulation (Delegated Regulation (EU) 2019/815) and digital tag the sustainability information contained therein (Article 29d of the Accounting Directive, Directive 2013/34/EU). EFRAG has developed a draft of the XBRL taxonomy required for the iXBRL tagging of ESRS disclosures and has conducted a public consultation on it. The final XBRL taxonomy is scheduled to be submitted to ESMA by the end of 2026. In the first quarter of 2027, ESMA will conduct a public consultation on amending the ESEF Regulation with regard to digital sustainability reporting and, in particular, propose rules for the application of the XBRL taxonomy.

In response to the CSRD requirements for digital sustainability reporting, the DRSC has entered into a partnership with XBRL Deutschland and established a working group. On April 8, 2024, the DRSC submitted a comment letter to EFRAG on the first draft of two XBRL taxonomies. On March 31, 2025, the DRSC submitted a comment letter to ESMA on the draft amendment to the ESEF Regulation. Finally, since 2019, the DRSC has been hosting a user forum on digital financial reporting under the ESEF Regulation, which offers DRSC member companies and associations exclusive insight into current developments and serves as a platform for discussing implementation issues.