At the end of July, EFRAG published proposed amendments to the CSRD reporting requirements. The aim is to simplify the framework, reduce confusion, and give companies more flexibility in how they present their sustainability information.

We spoke with SustainLab’s CSRD Specialist, Sofie Bjerling, to break down the most important changes and what they mean in practice.

1. Many data points have been removed. What’s changed?

Yes, the new proposal removes 67.6% of all data points (excluding the GDRs, which have been reduced by 26 % exclusively). That’s 726 in total, including all ‘may’ requirements and a large share of ‘shall’ requirements. The reason is to make reporting more manageable and to remove confusion about which requirements are mandatory. For companies, it means less information to report on, but also a need to focus on the essentials and ensure quality in the data that remains.

2. The list of sustainability matters have been updated. How?

Many companies seem to have treated the list of sustainability matters as a checklist, ticking them off one-by-one, with little focus on identifying entity-specific topics. The new proposal by EFRAG emphasise this list shall be considered a reference guide and that the reporting should be limited only to those that are material. The amendments made include a clear mapping between the different topics and the specific disclosure requirements (data points) to guide companies on what to report based on their materiality assessment. Additionally, they have deleted the lowest level (previously called sub-sub-topics) and replaced the term "sustainability matters" to "sustainability topics" to avoid too many overlapping terms. The good thing here is that EFRAG is encouraging companies to think more broadly and include the issues that are most relevant to their business - not getting lost in compliance exercises!

3. What does it mean that IROs and PATs should be more connected?

The relationship between the IROs (impacts, risks, and opportunities) and PATs (policies, actions, and targets) have not been so clear across the current ESRS. The update emphasise that these need to be connected - your policies, actions, and targets should directly address the material IROs you’ve identified. This strengthens the link between what you say is important and what you’re actually doing about it.

4. Sector-specific guidance is gone. How should companies handle that?

The reference to sector-specific ESRS standards has been removed. Instead, companies are encouraged to look at other frameworks, such as IFRS or GRI, for sector guidance. This means you’ll need to be proactive in finding relevant examples or best practices for your industry - it’s no longer provided directly in the ESRS.

5. There’s a change to how GHG boundaries should be defined. What’s new?

The proposal aligns more closely with the GHG Protocol, using the financial control approach as the default. If needed for fair presentation, companies should also report Scope 1 and 2 under the operational control boundary. This is about ensuring comparability across reporting companies as well as connecting the emissions reporting with the financial statement.

Not sure how to proceed? Continue with CSRD reporting or switch to VSME? Schedule a meeting with one of our experts for further guidance.


Watch our interview about the ESRS updates with Sofie below