Preliminary DRSC position on ED ESRS-40a

Today, the DRSC’s Sustainability Reporting Technical Committee published its preliminary position on the ED ESRS-40a. Following intense discussions, EFRAG issued the ED ESRS-40a for public consultation on 23 July 2026 (see our previous press release). The comment period ends on 31 October 2026.

With this pre-release, the DRSC seeks to inform the public discussion surrounding the ESRS-40a, highlight key areas of criticism regarding the current ESRS-40a draft standards, and put forward a more practical solution for discussion. The DRSC is convinced that there is a need for a worldwide mutual acceptance of national, supranational or international standards to jointly promote high-quality sustainability reporting. That said, we argue that the requirements laid down in the final ESRS-40a need to be significantly less complex than currently envisaged in the draft standards. The DRSC’s Sustainability Reporting Technical Committee’s key proposal is a “staggered approach”, where third-country undertakings are initially required to report only in accordance with ESRS-40a 2 together with the topical standards ESRS-40a E1, ESRS-40a S1 and ESRS-40a G1.