DRSC comments on EFRAG’s Draft of a New List of ESRS Datapoints

On October 23, 2026, the DRSC’s Technical Committee on Sustainability Reporting submitted comments to EFRAG regarding its draft of a new list of ESRS datapoints (LoD). The draft list reflects the ESRS as adopted by the European Commission in July 2026 through a Delegated Regulation, following EFRAG’s simplification of ESRS in 2025.

The list is intended to assist companies in preparing their sustainability statements in accordance with the revised ESRS.

The DRSC Technical Committee on Sustainability Reporting supports EFRAG in provided an updated list of data oints to assist in the application of the ESRS. However, this list should reflect the full disclosure requirements of the ESRS, as the abbreviated version in the list of datapoint list could lead to a misunderstanding of the ESRS disclosure requirements. Not only must the disclosure requirements themselves be fully reflected, but the Application Requirements (AR) that are not currently included in the LoD should also be listed if they contain disclosure requirements. Although it is not conceptually intended for ARs to contain disclosure requirements, the DRSC provides examples in the appendix to its comment letter showing that this is sometimes the case.