18. November 2025
ESRS revision: DRSC draws EFRAG’s attention to further critical issues in current discussion for revised ESRS
On November 14, 2025, the DRSC sent a letter to EFRAG highlighting what it considers to still be problematic aspects of the revision of the ESRS. The current status of the ESRS revision was previously discussed with the Technical Committee for Sustainability Reporting (FA NB) as well as with undertakings and auditors.
In light of these discussions the DRSC sees the risk of the revised ESRS not being widely accepted. This is due, on the one hand, to continuing conceptual ambiguities, such as with regard to the information materiality concept, the necessary definition of the users of sustainability information, or with regard to the assessment of material impacts, risks, and opportunities (formerly “gross/net”). Furthermore, the requirements for disclosures on anticipated financial effects remain too vague. On the other hand, the increased granularity of some disclosure requirements or newly introduced concepts are criticized. In the opinion of the DRSC, these preliminary considerations contradict the EU Commission’s stated objective of revising, clarifying, and simplifying ESRS Set 1. Please note, that on November 11, 2025, the DRSC sent a separate letter to EFRAG regarding the living wage concept.
The EU Commission has asked EFRAG to submit its proposals for the revised ESRS Set 1 by the end of November 2025. These current DRSC comments follow earlier comments on the Exposure Drafts for amended ESRS published by EFRAG in July 2025. Comments on these proposals had to be submitted until the end of September 2025. The DRSC had intensively discussed these EDs at the time and has since been following the discussion on the further development of the revised ESRS in EFRAG’s SRB and SR-TEG.
The DRSC, together with EFRAG representatives, will hold a public event on December 9, 2025, at 9 am on the revised ESRS submitted to the EU Commission at the end of November 2025.