ESRS Set 1 and VS: DRSC comment letters for the EU Commission

On 3 June 2026, the DRSC submitted a comment letter to the European Commission on the revision of the ESRS Set 1 (Delegated Regulation (EU) 2023/2772) and a further comment letter on the Voluntary Standard for Sustainability Reporting (VS).

Georg Lanfermann (DRSC President) commented: “This is expected to be the crucial step towards both the revision of the ESRS and the adoption of the VS. The DRSC would welcome the adoption of the delegated acts by July 2026 at the latest, in order to provide companies with the necessary legal certainty in their reporting.”

Topics covered in the comment letter on the revision of ESRS Set 1 include, in particular: disclosures on anticipated financial effects, requirements for the materiality analysis, transitional provisions, disaggregation levels, sector-specific disclosures, references to the Greenhouse Gas Protocol and the use of ILO principles.

Topics covered in the comment letter on the VS include, in particular, the design of the Value Chain Cap as well as suggestions for clarifications to enable a better understanding of the requirements.

These comment letters are the result of intensive discussions within the DRSC’s Sustainability Reporting Technical Committee, regular exchanges with practitioners, and a public information event held jointly with the European Commission on 12 May 2026. As part of the revision of ESRS Set 1, the DRSC had submitted a comment letter on EFRAGs Exposure draft technical advice in September 2025, and a further comment letter on EFRAG’s final technical advice to the BMJV in January 2026. As part of the development of the VS, the DRSC already submitted a comment letter in February 2026 to the BMJV on the Recommendation (EU) 2025/1710. In addition, in May 2026, a study prepared by the DRSC staff was published summarising various stakeholders’ views on this recommendation.