Revision of ESRS Set 1: DRSC response on EFRAG exposure drafts

On 29 July 2025, EFRAG published drafts of the revised ESRS Set 1 (Delegated Regulation (EU) 2023/2772). On 29 September 2025, the DRSC submitted its response to these consultation drafts to EFRAG using the online questionnaire provided for this purpose. In addition to detailed feedback at the level of reporting requirements (EFRAG’s EXCEL template), the DRSC summarised the key points of its response in a separate letter to EFRAG.

This letter addresses the following aspects:

• Fair presentation concept: The DRSC advocates further clarification to address existing uncertainties regarding the understanding of this concept in the context of sustainability reporting.
• Materiality of information: The DRSC supports emphasising the materiality principle at the information level. However, adjustments are necessary. For example, the concept of the decision-usefulness of information for all users of sustainability reporting should be the guiding principle for assessing the materiality of information.
• General disclosure requirements (GDR) – Policies and actions: In the exposure drafts, the distinction between the two aspects is not yet sufficiently specified from the DRSC’s point of view. The DRSC sees a need for conceptual improvement here.
• Gross vs. net consideration: Although the DRSC welcomes addressing this issue, there are still conceptual weaknesses in the draft. These are intensified by inconsistencies between the examples listed in Appendix C of ED ESRS 1 and the rules in the main body of the standard.
• Anticipated financial effects: On the one hand, the concept pursued by EFRAG about these effects has not yet been clearly elaborated. On the other hand, the DRSC has doubts about the reliability and informative value of quantified information on anticipated financial effects. The DRSC therefore advocates requiring only qualitative information (option 2 in EFRAG’s draft of ESRS 2).
• Climate scenario analyses: In the DRSC’s view, the use of climate scenarios should not be mandated by the ESRS. However, this should be explicitly stated in the ESRS.
• Transition plan for climate change mitigation: The DRSC welcomes the reduction in reporting requirements in ESRS E1 in this context but points out some expansions in requirements (e.g. description of the complete “financial and investment planning”) which should be avoided in view of the objectives associated with the revision.
• Extensions and additional data points: In addition to these identified extensions in ESRS E1, the DRSC noted further additional data points and extensions other draft ESRS. In this context, the DRSC once again refers to the European Commission’s mandate on reducing data points.

The separate letter to EFRAG and the detailed feedback as a table can be downloaded here (letter, table). Further responses to the EFRAG questionnaire will be made available shortly, as soon as EFRAG makes this technically possible.

The comment letter is the result of intensive discussions in the DRSC Sustainability Reporting Technical Committee, regular exchanges with practitioners, and a public outreach event on 18 September 2025.