Revision of ESRS Set 1: Field Tests

EGRAG invites sustainability report preparers to apply by 18 August 2025 to participate in the field tests on ‘Gross versus Net’ and the ‘Methodology for Non—EU Adequate Wages’. This call is related to the current consultation on the revision of ESRS Set 1 (Delegated Regulation (EU) 2023/2772) and is intended to assess the intended simplifications.

It is possible to participate in only one or both field tests. Interested parties can submit an application by 18 August 2025 to:

• grossnetfieldtest@efrag.org ‘Gross versus Net’
• fieldtestadeqwages@efrag.org ‘Methodology for Non—EU Adequate Wages’

EFRAG is looking for

• EU companies that included an ESRS sustainability statement for 2024 in their management report; and
• Groups with a non-negligible portion of the workforce receiving wages in non-EU countries (only relevant for the field test on adequate wages).

Participants need to complete a tailored questionnaire and take part in one-to-one interviews with the EFRAG Secretariat between 8 and 26 September 2025.

Field test ‘Gross versus net’

The ‘Gross versus net’ field test focuses on the new guidance for incorporating remediation, mitigation, and prevention actions into the Double Materiality Assessment (DMA). The new guidance is in ESRS 1 paragraphs 34-35, Application Requirements 12-13, and Appendix C.

Field test on the ‘non-EU adequate wages’ methodology

The Adequate Wages field test targets the revised methodology for calculating adequate wages for non-EU employees. The new methodology relates to ESRS S1-9 Adequate wages and the hierarchy for calculating adequate wages outside the EU as defined in the related Application Requirement.