ESRS revision: DRSC submits comment letter to the German federal ministry of justice BMJV

On 16 January 2026, the DRSC submitted a comment letter to the Federal Ministry of Justice and Consumer Protection (BMJV) on the final EFRAG technical advice for the ESRS revision, following a consultation request from the BMJV on 19 December 2025. The BMJV intends to use the feedback received from the DRSC and other organisations for further discussions on the ESRS revision at EU level. The DRSC will also forward the comment letter to the European Commission.

The comment letter is the result of intensive discussions in the DRSC’s Sustainability Reporting Technical Committee and regular discussions with practitioners. The DRSC emphasises that the EFRAG proposals represent significant improvements and simplifications of the ESRS in many respects. Nevertheless, the DRSC sees a need for further revision in three areas. These are areas in which the EFRAG proposals:

1. go beyond the previous requirements of ESRS Set 1 (Delegated Regulation (EU) 2023/2772),
2. contain requirements that are (still) unsuitable or unclear, and
3. contain requirements which are to be determined at the level of the European Commission.

In its comment letter, the DRSC focuses on the issues it considers most important and in need of further revision. The appendix to the comment letter addresses details to the areas mentioned above.