Further DRSC position paper on the revision of ESRS Set 1 – opening up ESRS for use of non-primary data and estimates

On June 3, 2025, DRSC submitted a further position paper on the revision of ESRS Set 1 to EFRAG. This paper addresses the need to collect and use primary data, which is – in Germany – a much-discussed ESRS requirement. In its position paper dated April 15, 2025, DRSC had already pointed out, among other things, that ESRS Set 1 should be opened up to the use of other available data and estimates for information on the value chain. The DRSC herewith takes up the point that such simplifications are generally also needed for ESRS disclosures on own operations. Acknowledging the preference for primary data and its essential role for sustainability reporting, nevertheless ESRS Set 1 should be opened up for other data sources in order to allow a more cost-benefit-efficient sustainability report.

On 15 April 2025 the DRSC had already submitted its position paper on the Revision of ESRS Set 1 to EFRAG. The paper outlines ten initial ideas developed by the DRSC’s Sustainability Reporting Technical Committee based on feedback received from preparers, auditors and other stakeholders.