Simplification of certain sustainability reporting standards

Dear Sir or Madam, Anthesis welcomes the opportunity to contribute to the EFRAG consultation on the European Sustainability Reporting Standards (ESRS). Drawing on our practical experience supporting companies across sectors in implementing CSRD requirements, we would like to share a set of targeted recommendations aimed at enhancing the clarity, consistency, and operational usability of the standards.

The Programme for the Endorsement of Forest Certification (PEFC) notes that the proposed delegated regulation to the ESRS continue to place significant emphasis on value chain impacts, due diligence, biodiversity, workers, communities, supplier relationship management and others.

CPP Investments is the professional investment management organization that invests Canada Pension Plan (CPP) funds not currently needed to pay benefits. Our legislated mandate, including maximizing returns without undue risk of loss, helps provide a foundation upon which the CPPs 22 million contributors and beneficiaries can build their financial security in retirement.

GCP Europe represents 400,000 companies and 2.5 million professionals in the building services engineering sector mechanical contractors, plumbers, HVAC and ventilation installers. Our member associations operate across 9 European countries, and our members are on the front line of delivering the EU's energy transition: they install and maintain the heat pumps, ventilation systems, hydronic networks and smart…

Germanwatch‘s respone to the draft revised European sustainability reporting standards We welcome several improvements in the revised ESRS standards:     The reaffirmation of double materiality and the clarification of the materiality-of-information filter are central to ensuring that disclosures are both comprehensive and decisionuseful.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The EDHEC Climate Institute welcomes the objective of simplifying the ESRS where simplification reduces unnecessary complexity, duplication and boilerplate reporting. A leaner and clearer set of standards can improve usability for preparers and users alike.

MATERIALITY welcomes the Commission's draft revised ESRS as a substantial step towards simplification. We strongly support the principle of fair presentation and the principle of double materiality, retained as the overarching and foundational principles of the standards, together with the high degree of interoperability with IFRS S1/S2 and the GRI.

The German Farmers’ Association (DBV) thanked for the opportunity to provide an opinion on the draft revised European sustainability reporting standards (ESRS). I. Introductory remarks The German Farmers’ Association (DBV) has been the central business association and stakeholders for agriculture and rural areas in Germany since 1948. More than 90 % of the more than 250.000 farms are voluntary members.

Filed in German · English published by the European Commission

Our members public and promotional banks across Europe are strongly committed to high-quality, comparable and decision-useful sustainability reporting. The present response sets out our overall position on the Commission's draft, together with detailed comments on specific Disclosure Requirements (DRs) where further clarification or adjustment would, in our view, materially improve the operability and usefulness of…

We welcome the European Commissions efforts to improve the usability, coherence and proportionality of the European Sustainability Reporting Standards (ESRS). Sustainability reporting should aim to provide comparable and useful information for companies, investors, civil society, affected communities and public institutions.

We welcome the European Commissions proposal as a positive step towards improving the readability, usability, and overall operability of sustainability statements. In particular, the proposed simplifications have the potential to support more focused and decision-useful disclosures while reducing unnecessary complexity for both preparers and users of sustainability information.

The Swiss Finance Council (SFC), the International Regulatory Strategy Group (IRSG), the Bank Policy Institute (BPI), UK Finance (UKF), the Japanese Bankers Association (JBA) and the Investment Association (IA) welcome the opportunity to contribute to the European Commission's consultation on the revised European Sustainability Reporting Standards (ESRS).

The European Construction Industry Federation (FIEC) welcomes the European Commissions efforts to simplify the European Sustainability Reporting Standards (ESRS) and acknowledges the substantial work undertaken by EFRAG and the Platform on Sustainable Finance to reduce reporting burdens and unnecessary compliance costs for companies.

We strongly support retaining the living wage reference in ESRS S1-9 (AR 20, paragraph 29) and endorse the use of ILO principles as agreed in the 2024 ILO Governing Body conclusions as the basis for assessing wage adequacy. It is essential that minimum wages are not treated as equivalent to adequate wages, as the two concepts are substantively distinct.

We welcome the fact that this proposal maintains double materiality as the basis for ESRS reporting. Some aspects have been clarified, such as the previously undefined and ambiguous term "adequate wages". This has been clarified in S1-9 (AR 20 for para 29) as: "the adequate minimum wage established by legislation or collective bargaining which provides a decent standard of living as confirmed by a calculation in…

Samsung Electronics (SE) acknowledges the intention of the Commission to simplify the EUs complex sustainability reporting framework (CSRD) through inter alia the simplification of the European Sustainability Reporting Standards (ESRS).

As the Responsible Business Forum (Forum Odpowiedzialnego Biznesu, FOB) the longest-running and largest non-governmental organisation in Poland comprehensively dedicated to the concept of sustainable development we see value in building a strategic business approach to ESG issues.

The Policy Hub welcomes the European Commission's efforts to revise the European Sustainability Reporting Standards (ESRS) in the context of the Omnibus I simplification package. The revised standards reflect a genuine commitment to streamlining reporting obligations, reducing duplication, and improving the overall coherence of the sustainability disclosure framework.

Wage setting is a matter that must respect national sovereignty, labour institutions in each country, collective bargaining processes, economic realities, productivity levels, social protection systems and the local structures of the Casto de vida.

Filed in Spanish · English published by the European Commission

As the Responsible Business Forum, the largest and longest-running non-governmental organisation in Poland dedicated to sustainable development, we recognise the importance of taking a strategic approach to environmental, social and governance (ESG) issues. A key part of this approach is reliable reporting on environmental, social and corporate governance issues.

We welcome the fact that, with the adopted omnibus package, the European Commission is reducing unnecessary bureaucratic burdens on small and medium-sized enterprises and easing the burden on reporting entities. The revised ESRS standard can contribute to this.

GSMA and Connect Europe welcome the opportunity to provide feedback on the European Commissions draft revised European Sustainability Reporting Standards (ESRS). Overall, we support the simplification of the ESRS framework and the objective of reducing reporting burden and improving usability.

WageIndicator Foundation welcomes the opportunity to provide feedback on the new proposed ESRS as part of its public consultation process. It notes that the new ESRS remains closely aligned with the UN Guiding Principles on Business and Human Rights, the Corporate Sustainability Due Diligence Directive, other existing frameworks in the EU such as the Adequate Minimum Wage Directive, and the reality of how many…

Joint Consultation Paper amending Delegated Regulation (EU) 2023/2772 as regards the simplification of certain sustainability reporting standards The EU Federation for the Factoring and Commercial Finance Industry (EUF) is the industry body and voice for the European factoring industry (EU transparency register no. 39275004756-35).

E3G welcomes the European Commissions decision to broadly align the draft revised European Sustainability Reporting Standards (ESRS) Delegated Act (DA) with EFRAGs final advice on the simplified reporting standards. Nonetheless, certain elements within the draft ESRS DA risk undermining the data quality and comparability of sustainability disclosures.

DIGITALEUROPE welcomes the Commission's efforts to simplify the European Sustainability Reporting standards (ESRS) and recognises further meaningful progress from the draft amended ESRS published by EFRAG in December 2025. In particular, we welcome the restored flexibility on Greenhouse Gas (GHG) reporting boundaries, improved omission provisions, new phase-in reliefs, and clarified materiality assessment.

Paris, June 3rd, 2026 Subject: Feedback from Middlenext on the Draft Delegated Regulation on the Simplification of Sustainability Reporting Standards. Middlenext is the independent business association representing French mid-cap listed companies. We are a privileged interface between listed company directors, institutional players, public authorities.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Michelin is pleased to share its assessment and key recommendations on the revision of ESRS. A well-designed framework can harmonise ESG reporting, improve transparency, accountability and comparability, and help prevent greenwashing, while supporting the transition to a sustainable economy.

The French Banking Federation (FBF) welcomes the European Commissions efforts to further simplify the ESRS, by reducing workload and unnecessary costs for companies. Overall, the proposed simplification of the standards is consistent with the balance long advocated by the FBF between reducing the reporting burden and preserving the ambition of the EU Green Deal and the integrity of the EU sustainable finance…

On 6 May 2026, the EU Commission posted the draft delegated acts amending the reporting requirements in the ESRS after EFRAG's recommendations earlier this year. Ørsted would like to provide feedback to the proposed ESRS through the comments attached.

Boston Trust Walden is an independent and employee-owned organization that provides asset management products and services to individuals and institutional investors. Our organization manages $14.9 billion in client assets. We specialize in actively managed multi-asset and equity portfolios for individual and institutional investors.

Positive Impacts (PI) GmbH welcomes the effort to simplify and improve the ESRS. Our feedback focuses on a fundamental observation: sustainability is not primarily a reporting challenge, but a performance and strategy challenge. While sustainability is increasingly embedded in governance and reporting structures, many organizations still struggle to identify a clear business case.

Milieudefensie (Friends of the Earth Netherlands) response to the European Commission consultation on the revision of the European Sustainability Reporting Standards Milieudefensie’s 2026 assessment of the climate plans of 28 Dutch companies and financial institutions, conducted by NewClimate Institute, underscores the importance of the Corporate Sustainability Reporting Directive (CSRD) and the European…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

As a Wave 1 company, Nokia published its first CSRD-aligned Sustainability Statement in March 2025. We believe that effective sustainability reporting and robust due diligence processes support high ambition levels by providing a strategic driver for performance improvement, while pragmatic implementation enables businesses to ensure compliance and to meet their customers' expectations quickly and in a…

As a global asset manager, Neuberger relies on high-quality, comparable sustainability reporting from the companies in which we invest to support our investment analysis, stewardship activities, and obligations to our own clients and regulators.

Cotton Incorporated submits these technical comments on the microplastics provisions of the revised ESRS (ESRS E2 Pollution, Disclosure Requirement E2-4, and the Annex II glossary term "Microplastics"). We comment as a technical provider of textile life-cycle and plastic-leakage research; our aim is methodological completeness and decision-usefulness, not advocacy for any fiber.

We welcome the proposal to maintain double materiality as the basis for ESRS reporting (ESRS 1, 3.1) We note that the removal of specified metrics for ESRS E4 will cause companies to expend time and resources to identify appropriate metrics.

The Sustainability and ESG Professionals Association (SEPA) welcomes the European Commissions efforts to simplify the European Sustainability Reporting Standards (ESRS) and supports reducing unnecessary reporting burdens while preserving decision-useful sustainability information.

Finnish Energy broadly welcomes the proposed revisions to the European Sustainability Reporting Standards (ESRS). The direction towards simplification, improved usability, and a stronger focus on material information is positive and aligns with the objective of reducing unnecessary reporting burden for companies. However, we still see a need for some clarifications and amendments. Please find our feedback attached.

The Aquaculture Stewardship Council (ASC) would like to thank the Commission for the opportunity to provide feedback in the context of the simplification process of the European Sustainability Reporting Standards (ESRS). Please find our recommendations in the attached document.

Assirevi welcomes the ECs draft Delegated Regulation and generally supports the changes made to EFRAGs technical advice. However, several technical aspects require further clarification and amendment to ensure effective implementation and to enable information prepared in accordance with the revised standards to be subject to assurance procedures.

ISEAL supplementary feedback on revised draft European Sustainability Reporting Standards (ESRS): Focus on Living Wages This submission complements ISEALs broader feedback on the revised draft European Sustainability Reporting Standards (ESRS) and focuses specifically on the treatment of living wages within ESRS S1-9.

Industry: Technology & Professional Services (Software, IT Services) We strongly support the direction of the revised ESRS 2.0. We commend the Commission for the significant simplification effort reflected in this draft and urge that it be finalized without reintroducing any removed data points.

Paragraph 19 of the proposed voluntary standard will avoid duplicate reporting and hence reduce administrative burdens. We suggest amending the paragraph to simplify reporting in the same way for undertakings, including many SMEs, with third-party certified environmental management systems recognized under EU law.

Danish Industri welcomes the opportunity to comment on the Revised European sustainability reporting standards (ESRS revised). We fully support the efforts with Omnibus I to ensure the competitiveness of Europe and reducing the administrative burdens of sustainability reporting while safeguarding the green deal policy goals.

Global Perspective Our members work with businesses subject to ESRS across Europe and globally. We have consistently advocated for alignment with ISSB standards, including concepts requirements and terminology. Many jurisdictions have adopted ISSB S1 and S2 in full, or with limited adaptations.

Verisure welcomes the European Commissions efforts to simplify and revise the European Sustainability Reporting Standards (ESRS) following the first phase of implementation. We consider this revision exercise both timely and necessary to ensure that the framework remains operational, proportionate and capable of delivering decision-useful sustainability information while reducing unnecessary complexity and…

Cascale welcomes the European Commissions efforts to improve the coherence, proportionality, and usability of the European Sustainability Reporting Standards (ESRS) while maintaining access to reliable, comparable, and decision-useful sustainability information throughout global value chains.

Ingka Group is the largest IKEA franchisee, operating 620 IKEA retail locations in 32 countries, alongside worldwide IKEA e-commerce and digital solutions. With over 160,000 co-workers, our reach is strengthened by our network of meeting place shopping centres and an active investment arm supporting sustainable growth.

The European Automobile Manufacturers Association appreciates the Commissions efforts to achieve simplification in the area of sustainability reporting standards and this proposal. However, further clarifications and simplifications will be key to achieve meaningful results for companies. Please see attached our comments.

The workers employed by my company are covered by collective bargaining agreements and by the statutory minimum wage system in force in Colombia, a mechanism that is established annually by government decree based on criteria including inflation, productivity, and standards of living.

We welcome the inclusion of ESRS E1-9 on GHG removals and GHG mitigation projects financed through carbon credits. The draft requires undertakings to disclose carbon credits verified against recognised quality standards and, where public GHG neutrality claims involve credits, to explain the credibility and integrity of those credits by referring to recognised quality standards and any other factors necessary to…

ETSA welcomes the European Commissions efforts to simplify the European Sustainability Reporting Standards (ESRS) while preserving the core objectives of the Corporate Sustainability Reporting Directive (CSRD). The textile services sector strongly supports a pragmatic and proportionate sustainability reporting framework that enables companies to focus resources on meaningful sustainability action, competitiveness…

As representatives of a major producer group, we believe that any living wage benchmark should be grounded primarily in International Labour Organization (ILO) standards and in the social dialogue processes embodied through collective bargaining.

ESRS 1 and 2 Fair presentation: despite the introduction of welcome clarifications, we are opposed to the introduction of this concept, in particular for the complexity of auditing. Anticipated financial effects: Despite the welcome introduction of relief without time limits and the alignment with the ISSB, we call for the transitional arrangements to cover climate-related quantitative information.

Filed in French · English published by the European Commission

The European association for ferro-alloys and silicon producers, Euroalliages, welcomes the opportunity to provide feedback on the revision of the simplified European Sustainability Reporting Standards (ESRS). We support the European Commission's efforts to reduce administrative burdens on companies, improve the usability of sustainability reporting, and ensure that reporting requirements remain proportionate…

The Better Cotton Initiative (BCI) welcomes the opportunity to provide feedback on the revised European Sustainability Reporting Standards (ESRS). As a global multi-stakeholder initiative representing 2 million cotton farmers and over 2,500 supply chain actors, BCI supports the development of a robust, credible and internationally aligned sustainability reporting framework that reflects real-world impacts across…

Comments for public consultation Draft amending Delegated Regulation simplifying the ESRS Subject: Draft Commission Delegated Regulation amending Delegated Regulation (EU) 2023/2772 as regards the simplification of certain sustainability reporting standards (Ref. Ares(2026)4623964).

On behalf of the American Property Casualty Insurance Association (APCIA), we appreciate the opportunity to engage in the ongoing process to revise and simplify the European Sustainability Reporting Standards (ESRS) under the Corporate Sustainability Reporting Directive (CSRD), and we intend to remain constructively involved throughout the consultation. APCIA represents U.S.

We welcome the European Commissions proposal as a positive step towards improving the readability, usability, and overall operability of sustainability statements. In particular, the proposed simplifications have the potential to support more focused and decision-useful disclosures while reducing unnecessary complexity for both preparers and users of sustainability information.

As a banana producer based in LaTam with direct commercial relationships with European companies subject to the CSRD, I submit this comment regarding Disclosure Requirement S1-9 and, in particular, Application Requirement AR 20 on adequate wage benchmarks applicable outside the European Union.

ANCE welcomes the simplification effort made by the European Commission in the revision of the ESRS, highlighting positively the reduction of mandatory data points, the distinction between mandatory and voluntary information, the strengthening of the principle of materiality and the introduction of more flexibility elements.

Filed in Italian · English published by the European Commission

EuroCommerce is the principal European organisation representing the retail and wholesale sector. We welcome the work of EFRAG and the Commission to simplify and streamline the ESRS and adopt the VSME standard. In our feedback, we would like to provide further input and suggestions for the improvement of both standards.

RECS welcomes the opportunity to provide feedback on the proposed amendments to Delegated Regulation (EU) 2023/2772 concerning the simplification of the European Sustainability Reporting Standards (ESRS). Please find our detailed comments below.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Connect Europe and the GSMA would like to thank the European Commission for giving stakeholders this opportunity to provide feedback on the draft Revised European sustainability reporting standards (ESRS). Please find attached our joint submission. Kind regards, [name removed] on behalf of Connect Europe

Schneider Electric welcomes the opportunity to provide feedback to the European Commission on the revised European Sustainability Reporting Standards (ESRS). We support the European Commission's intention to simplify the ESRS, in line with the initial work made by EFRAG.

Fecc welcomes the opportunity to provide feedback on the Commissions proposal for Voluntary Sustainability Reporting Standards for SMEs (VSME), supporting the objective of a proportionate tool that facilitates sustainability data sharing across value chains.

A response from Global Canopy 1) Ensure a robust materiality assessment for nature-related issues: a) Clarify that the determination of which activities are a significant driver of impacts, risks or opportunities (ESRS 1 para 90), must be based on a robust materiality assessment.

Buzzi S.p.A. supports the European Commissions initiative to review the simplified ESRS, emphasizing the need for a clear, proportionate, and decision-useful framework that focuses on material and verifiable information while safeguarding competitiveness and confidentiality.

Caisse des Dépôts, Frances National Promotional Institution and one of the countrys largest financial groups, is a main actor in financing sustainability and a long-term institutional investor with a deep commitment to responsible investment. Sustainable development lies at the heart of our mission and values, and we have consistently supported the ambition of the EU Sustainable Finance Framework.

Independent Retail Europe represents the independent retail sector. Independent retailers are privately owned and operated store-based or multichannel retail businesses. These retailers may function under the umbrella of a larger cooperative or voluntary retail group that ensures entrepreneurial autonomy while offering certain shared resources, such as joint buying and marketing, branding, and infrastructure of…

A reporting system supporting a more efficient building stock Efficient Buildings Europe supports the objective of simplifying ESRS and reducing unnecessary reporting burden. However, simplification should not remove the core, comparable information needed to finance the decarbonisation of Europes building stock.

Chartered Accountants Ireland observations on ESRS response to the European Commission call for views Chartered Accountants Ireland welcomes the finalisation of the draft simplified ESRS and, in particular, we welcome the clarity that this provides for reporting entities.

Bloomberg L.P. 3 Queen Victoria Street London, EC4N 4TQ United Kingdom 3 June 2026 Bloomberg response on the revised European sustainability reporting standards (ESRS) Bloomberg welcomes the European Commission’s initiative to streamline the European Sustainability Reporting Standards (ESRS) while preserving their role as a cornerstone of the EU sustainable finance framework.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

PostEurop welcomes the European Commission initiative to review the EU ESRS and to update and simplify the criteria. Please find attached PostEurop's position based on the practical experience of its members in the implementation of sustainability reporting.

Copper is essential to Europes decarbonisation, electrification and competitiveness objectives. As the global economy transitions towards clean energy technologies and higher living standards, demand for copper is expected to increase significantly. Copper demand is projected to grow by 35% in the European Union and to double globally by 2050.

The European Biogas Association (EBA) welcomes the simplification efforts undertaken with the revision of the ESRS and recognises progress made in the draft delegated act, particularly under Disclosure Requirement E1-8 and related Application Requirements (ARs).

The VDMA acknowledges that the Commission has improved the draft in several respects compared to EFRAGs technical advice. Notable adjustments include clarifications on user needs, selected structural improvements to the materiality assessment, and the extension of certain reliefs.

FTN (Federatie Textielbeheer Nederland) represents the Dutch textile services sector and supports the objectives of the Corporate Sustainability Reporting Directive. Sustainability reporting can improve transparency, strengthen decision-making and support the transition to a more sustainable economy.

The Agence Française de Développement (AFD) Group, a French Public Development Bank, contributes to the commitment of France to support the Sustainable Development Goals, through the provision of financial assistance notably in the form of loans, outside the EU for the largest part. Since 2017 it formally engaged in systematically supporting low carbon and resilient transition of developing and emerging countries.

In line with the French Afep-MEDEF, French GIFAS and European ASD responses, Dassault Aviation has selected a limited number of critical points related to issues still needed to be addressed to make ESRS the appropriate instrument for the competitiveness of European companies. These critical points are listed on attached PDF doc.

The Institute of International Finance (IIF) welcomes the opportunity to provide feedback on the European Commissions draft revised European Sustainability Reporting Standards (ESRS), which aim to reduce reporting burdens while preserving the quality and usefulness of sustainability disclosures.

Siemens Energy appreciates the opportunity to contribute to the consultation of the revised ESRS. While we welcome the Commission’s efforts to simplify the ESRS, we have identified five priority areas where adjustments would significantly improve consistency, comparability and implementation feasibility: 1. 2. 3. 4. 5.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Decathlon welcomes the Commissions consultation on the revised European Sustainability Reporting Standards, following the text published by EFRAG in December 2025. However, there are certain aspects that would require further development of clarification. Please find attached the detailed position of Decathlon.

French companies acknowledge the Commissions important efforts to further simplify the ESRS by reducing workload and unnecessary costs for companies. The following issues still need to be addressed to make ESRS a useful instrument serving the transition.

IOGP Europe welcomes the progress made by the European Commission in the revised draft Sector-Agnostic European Sustainability Reporting Standards (ESRS) published as part of the Omnibus I simplification package.

Social factors and Disability content should be maintained and reinforced in the simplified ESRS CERMI welcomes the opportunity to provide feedback on the Commissions proposal for a delegated regulation regarding the simplification of the European Sustainability Reporting Standards (ESRS) under the Corporate Sustainability Reporting Directive (CSRD).

AFME Recommendations on European Commission Draft Revised ESRS 3 June 2026 The review of the ESRS is a critical element of the Commission’s Sustainability Omnibus initiative and a vital lever for delivering simplification. AFME strongly supports the orientations set out by the Commission for the revision of the ESRS, which co-legislators have endorsed in the final Omnibus I text.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

WELLINGTON MANAGEMENT COMPANY LLP Ref. Ares(2026)5656277 - 03/06/2026 280 Congress Street, Boston, Massachusetts 02210 USA T +1 617.951.5000 | F +1 617.951.5000 | F +1 617.951.5000 Client Service www.wellington.com 3 June 202 6 Dear European Commission , Wellington Management Company LLP (“Wellington”) commends the enhance d standardization of sustainability related disclosures in the draft Delegated Regulation on r…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Japan Business Council in Europe (JBCE) welcomes the opportunity to comment on the European Commissions proposed Delegated Regulation amending Delegated Regulation (EU) 2023/2772 as regards the simplification of certain sustainability reporting standards (ESRS) .

The Institut de la Finance Durable (IFD) welcomes the Commissions draft Delegated Regulation amending the ESRS, published on 6 May 2026. Overall, the proposed simplification of the standards is consistent with the balance long advocated by the Paris financial centre between reducing the reporting burden and preserving the ambition of the EU Green Deal and the integrity of the EU sustainable finance framework.

The Dutch Fund and Asset Management Association (DUFAS) welcomes the European Commissions proposed revision of the European Sustainability Reporting Standards (ESRS), which strike an appropriate balance between simplifying reporting requirements and preserving the core principle of double materiality.

Cefic welcomes the Commissions efforts in addressing existing concerns in the EFRAG technical advice from December 2025. We reiterate that the goal of the Omnibus I Directive is to deliver a meaningful reduction in compliance costs without compromising decision-useful transparency.

The amendments to the sustainability integrators were decided too early without an adequate time period for consistent compliance. Workers’ indicators in sustainability budgeting are crucial for us. There is a risk that useful indicators for assessing the impact of businesses on food will no longer be available.

Filed in Italian · English published by the European Commission

The European Commissions efforts to simplify the European Sustainability Reporting Standards (ESRS) in the May 2026 publication are constructive and include improved consistency across standards, closer alignment with international frameworks such as the International Financial Reporting Standards (IFRS) Sustainability Disclosure Standards and targeted relief for preparers.

Banca Popolare Etica is an Italian ethical cooperative bank whose core mission is to finance social economy organisations, environmental initiatives and social enterprises. As a financial institution whose activity is grounded in the social and environmental impact of lending and investment, we have a direct interest in the quality and reliability of sustainability reporting standards.

The European Public Real Estate Association (EPRA) represents the listed real estate sector in Europe. Our association represents more than 280 members (companies, investors and their suppliers) and over 930 billion EUR of real estate assets (European companies only) including Real Estate Investment Trusts (REITs) which are companies that own, develop and trade investment property, to investors whether pension…

This document contains detailed comments on the draft revised European Sustainability Reporting Standards (ESRS). Materiality. A major point to be criticized is the large role that materiality plays in the Set 1 ESRS, which has been increased even further in the draft revised ESRS.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Recommendation to explicitly recognise the use of CEN, CENELEC, ISO and IEC Standards in ESRS We welcome the ongoing review of the ESRS. Explicitly recognising the possibility for undertakings to disclose the implementation of relevant CEN, CENELEC, ISO and IEC standards would strengthen the quality, consistency and credibility of reported information, contribute to regulatory coherence, reduce reporting burdens and…

As a member of the German Bundestag and rapporteur for the CDU/CSU parliamentary group on company and business law, I take the opportunity to comment, in the context of the European Commission’s public consultation, on the draft delegated regulations published on 6 May 2026 – on the simplification of the European Sustainability Reporting Standards (ESRS) and on the introduction of a voluntary sustainability standard…

Filed in German · English published by the European Commission

InterIKEA Group welcomes the continued development of the European Sustainability Reporting Standards (ESRS), as a step of the implementation of the Corporate Sustainability Reporting Directive (CSRD),andrecognisesthe progress made towards smart simplification, striking a better balance between ambition and usability.

The large, internationally operating family businesses which our Foundation represents support the European Commission´s general approach to overhaul and simplify the European Sustainability Reporting Standards (ESRS). The simplification drafts by EFRAG structurally dissolve various textual und content-related duplications. The stronger focus e.g. on key actions would allow for a more proportional reporting.

The Dutch Accounting Standards Board (DASB) appreciates the opportunity to respond to the revised and simplified European Sustainability Reporting Standards (ESRS) released for public consultation by the European Commission on 6 May 2026. We include our feedback on the ESRS in the attached letter. The DASB welcomes most of the revisions introduced by the European Commission.

Dassault Systèmes fully supports the objectives of the ongoing ESRS revision and welcomes the opportunity to contribute to the ongoing revision process of the European Sustainability Reporting Standards. Please find an executive summary of Dassault Systèmes recommendations on the proposed draft below and our detailed recommendations within the attached file.

1. ESRS 1 Chapter 3.1.2 & 3.1.3: Materiality Assessment ("Top-Down" Approach) Reference: Paragraph 27; Chapter 3.1.3 Position: We support the "top-down" approach to de-scope non-material topics but caution against over-simplification that risks ESG-lite reporting. Rationale: While reducing reporting burden is welcome, de-scoping sustainability topics must remain credible.

European Association of Co-operative Banks (EACB) welcomes the European Commissions efforts to revise the ESRS with the objective of creating a more targeted, proportionate and practical sustainability reporting framework under the CSRD.

The review of the European Sustainability Reporting Standards (ESRS) is an important opportunity to advance transparent sustainability reporting. Bayer acknowledges the European Commissions draft Delegated Act published on 8 May 2026 and appreciates the efforts made to introduce targeted improvements to EFRAGs final report.

Deutsche Börse Group (DBG) welcomes the opportunity to comment on the draft Delegated Regulation containing revised ESRS. As a leading European market infrastructure provider, DBG is committed to fostering a robust, transparent and efficient EU single market for sustainable finance. An effective, proportionate and globally aligned sustainability reporting framework is an essential cornerstone for this.

June 2026 Submitted: Via European Commission Portal RE: Response to European Commission Consultation on the Revised ESRS Minerva Analytics welcomes the opportunity to respond to the European Commission’s proposed changes to the ESRS framework and objective aim of simplifying and streamlining the ESRS reporting requirements while preserving the key aims of CSRD.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

1. Narrowing down the definition of 'user' (ESRS 1 AR Para. 4(b)) The definition of "other users" under ESRS 1 AR para. 4(b) remains too broad and unclear, creating legal uncertainty and the risk of inconsistent interpretation across companies and auditors.

Grant Thornton International Ltd (GTIL) is pleased to comment on the European Commissions (EC) draft Delegated Regulation amending and simplifying ESRS. Firstly, we are pleased to see this project coming to its conclusion. There has been an extended period in which reporting entities have been dealing with uncertainty on sustainability reporting requirements.

CLEPA supports a focused revision of the ESRS to improve proportionality, legal certainty and auditability, drawing on first-wave implementation experience. The priority should be to meaningfully reduce reporting complexity while keeping sustainability reporting decision-useful.

ExxonMobil strongly supports efforts to strengthen Europes industrial competitiveness and maintain its attractiveness for energy intensive and strategically important sectors. We therefore welcome the European Commissions ongoing efforts to enhance economic competitiveness, including through the Omnibus initiatives and its ambition to reduce regulatory burdens.

IMA-Europe Position on ESRS revision by EFRAG (03.06.2026 – FINAL) The Industrial Minerals Association Europe (IMA-Europe/IMA), representing the interest of Industrial minerals producers in Europe, supports the overarching goal of sustainability and transition.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

3 June 2026 Mr Sven Gentner European Commission Rue de la Loi 200 1049 Brussels Subject: PwC response letter to the European Commission’s draft Delegated Regulation amending Delegated Regulation (EU) 2023/2773 regarding revised European Sustainability Reporting standards (ESRS Delegated Act) Dear Sven, PwC International Limited (PwC)1, on behalf of the PwC network, appreciates the opportunity to provide feedback on…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Commenti Confindustria Standards (ESRS) – – Revisione degli European Sustainability Reporting Confindustria riconosce e apprezza gli sforzi compiuti dalla Commissione per ridurre il carico di rendicontazione per le imprese.

Filed in Italian · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

At IAG, our purpose is to connect people, businesses and countries using aviation as a force for good. We believe in the transformative power of flight: enabling personal and professional connections, supporting global trade and fostering the discovery of new places, ideas and experiences.

03 June 2026 Eurogas Position on the Revised European Sustainability Reporting Standards (ESRS) Eurogas welcomes the efforts by EFRAG and the European Commission to simplify the ESRS. The revised standards are overall clearer and better structured, with some improvements.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Feedback on the Draft Revised European Sustainability Reporting Standards (ESRS) HCL Technologies Ltd. welcomes the European Commission’s initiative to simplify and refine the European Sustainability Reporting Standards (ESRS), while maintaining the core objectives of transparency, comparability, and decision‑useful sustainability reporting.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Malta Institute of Accountants Feedback on revised sustainability reporting standards The revised European Sustainability Reporting Standards represent a significant shift toward simplification and cost reduction. The overall direction is positive, with the draft achieving a two-thirds reduction in mandatory datapoints while maintaining focus on material sustainability impacts, risks, and opportunities.

WeeFin is an impact fintech whose objective is to raise the standards of sustainable finance and operates at the intersection of various players in the financial sector: asset owners, asset managers, as well as private data providers and public sources. This central position gives us a practical understanding of the challenges involved in sustainable finance regulations and data. 1.

Repsol welcomes the opportunity to contribute to the European Commissions call to this public consultation and acknowledges the endeavor of EFRAG and the European Commission in the overwhelming task of simplifying the Sector-Agnostic European Sustainability Reporting Standards (ESRS Set 1).

June 2026 DHL Group Contribution - Revised European Sustainability Reporting Standards Draft Commission Delegated Regulation to (EU) 2023/2772, Annex I-II (as published 6 May 2026) At DHL Group, we are firmly committed to fulfilling our sustainability responsibilities under the European Sustainability Reporting Standards.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Insurance Europe and the European Insurance CFO Forum welcome the clarifications introduced on the fair presentation concept, the confirmation that reliefs (section 7.3) will be maintained on a permanent basis, the guidance on the use of reasonable and informed judgement and the specifications on the top-down approach.

The BDI welcomes the opportunity to comment on the published draft. Some of the improvements of the revised ESRS are highly appreciated. However, the BDI remains concerned that the proposed amendments do not yet go far enough to meaningfully reduce the complexity and administrative burden associated with the ESRS framework in Europe.

The German airport sector welcomes the European Commissions proposal to simplify the European Sustainability Reporting Standards (ESRS) under the Omnibus I package. The reduction of mandatory datapoints, the strengthened role of materiality and the simplification of value-chain reporting are important steps towards a more proportionate and effective sustainability reporting framework.

Position Paper CEMENT EUROPE FEEDBACK ON THE REVISED EUROPEAN SUSTAINABILITY REPORTING STANDARDS 3 June 2026 Cement Europe welcomes the opportunity to provide comments on the revised European sustainability reporting standards, based on the input received from its members.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

As a company committed to building a sustainable future, Siemens Healthineers welcomes the efforts undertaken by EFRAG and the European Commission to simplify the European Sustainability Reporting Standards (ESRS).

Italgas supports the European Draft Act on the simplification of the European Sustainability Reporting Standards (ESRS) and, in particular, welcomes a number of positive developments introduced in the revised framework. However, we consider that there remains scope for further simplification and improvement, and therefore call upon the Commission to address the aspects outlined below.

Social factors and Disability content should be maintained and reinforced in the simplified ESRS ONCE Social Group welcomes the opportunity to provide feedback on the Commissions proposal for a delegated regulation regarding the simplification of the European Sustainability Reporting Standards (ESRS) under the Corporate Sustainability Reporting Directive (CSRD).

From the point of view of local government, the proposed simplification of ESRS is to be welcomed. It is also important to continuously revise the data points. The significant reduction in the number of data points to be disclosed represents a good balance between simplification and obtaining the necessary information to meet the objectives of the Green Deal.

Filed in German · English published by the European Commission

European Commission Brussels 3 June 2026 Dear Sir/Madam Public consultation on the European Commissions draft Delegated Regulation amending Delegated Regulation (EU) 2023/2772 regarding revised ESRS We welcome the opportunity to comment on the draft Delegated Regulation. Following consultation with the BDO network, this letter summarises views of member firms that provided comments on the above document.

The Danish National Funding Mechanism for EFRAG (DK NFM) welcomes the opportunity to comment on the Revised European sustainability reporting standards (ESRS revised). We representing preparers, financial institutions (users and preparers) and auditors - fully support the efforts with Omnibus I to ensure the competitiveness of Europe and reducing the administrative burdens of sustainability reporting while…

OFICEMEN welcomes the Commissions objective of simplifying the European Sustainability Reporting Standards and reducing unnecessary reporting requirements. Please find attached OFICEMENs comments on the draft revised ESRS.

Revised ESRS May 2026 - Comments Topic ESRS Own workforce S1 DR (ESRS May 2026) AR 9 Own workforce S1 Biodiversity # Statkraft Internal E4 E4-5 # E4-5 Biodiversity E4 Biodiversity E5 Biodiversity E4 E4-5 ESRS 1 ESRS 1 ESRS 1-10 ESRS 1 ESRS 1 ESRS 1-3.2.1 Statkraft Internal # ESRS 1 ESRS 1 ESRS 1-3.2.2 ESRS 1 ESRS 1 ESRS 1-5.1 ESRS 1 ESRS 1 ESRS 1-5.2 Climate ESRS E1 E1-6 Climate ESRS E1 E1-6 Statkraft Internal #…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

CNA welcomes the revision of the European Sustainability Reporting Standards (ESRS) as an opportunity to improve their usability and ensure a more proportionate framework. At the same time, simplification should not lead to a weakening of the overall EU sustainability framework.

The Responsible Business Alliance (RBA) welcomes the European Union's efforts to streamline the EU sustainability reporting standards, while preserving the policy objectives underlying the EU Corporate Sustainability Reporting Directive.

The Banana and Plantain Cluster of Ecuador supports the objectives of sustainable and transparent value chains. At the same time, sustainability reporting requirements should remain proportionate, risk-based and practical, particularly for suppliers located outside the European Union.

Response to the European Commission’s Public Consultation on the Revised ESRS – June 2026 Rights Advisory welcomes the Commission’s continued alignment of the revised ESRS with the UN Guiding Principles on Business and Human Rights (UNGPs) and the CSDDD. The standards appropriately reflect a risk-based approach to material impact reporting and require disclosure across all stages of due diligence.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Oslo, June 3rd, 2026 Norwegian Shipowners’ Association Feedback on the European Commission’s Consultation on the Revised ESRS The Norwegian Shipowners’ Association (NSA) would like to thank the European Commission for the opportunity to provide feedback to the revised European sustainability reporting standards.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Confederation of Swedish Enterprise welcomes the opportunity to respond to the public consultation on the revised European Sustainability Reporting Standards (ESRS). The implementation and initial years of reporting under ESRS Set 1 have provided clear evidence that the current framework is overly complex and disproportionate in relation to its objectives.

Norges Bank Investment Management (NBIM) is the investment management division of the Norwegian Central Bank (Norges Bank). As an overarching observation, we consider simplification and interoperability with the International Sustainability Standards Board (ISSB) Standards to be complementary rather than competing objectives.

Feedback on AR 15 (paragraph 32): Characteristics of severity and time horizon I welcome the Commission's effort to reduce the burden of the double materiality assessment (DMA). However, the current AR 15 wording falls short of meaningful relief and, in some respects, codifies the most burdensome interpretation of the original ESRS. 1.

European Commission Attn. Ms [name removed] Commissioner for Financial Services and the Savings and Investments Union cc. Ms [name removed] cc. Mr [name removed] 03 June 2026 VEUO E [email removed] T [phone removed] Subject: VEUO response to revised European Sustainability Reporting Standards Dear Madam, Sir, The VEUO, the representative association of Dutch listed companies, thanks the European Commission (the…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EFFAS, the European Federation of Financial Analysts Societies, supports efforts to streamline reporting requirements where appropriate. However, simplification should not undermine the core objective of the CSRD, which is to ensure the availability of credible, comparable, and decision-useful sustainability data.

POSITION PAPER ESRS Draft Delegated Act Public Consultation– FEB Answer Rodolphe Mouriau Deputy Adviser Competence centre [Sustainability & Circular Economy] [email removed] Publication date / 03 June 2026 The Federation of Entreprises in Belgium (FEB) welcomes the European Commission’s efforts to revise the European Sustainability Reporting Standards (ESRS) and recognises the improvements made compared to earlier…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ABI supports the approach of the Delegated Act, relying on the EFRAG proposal, considered a balanced solution. We welcome the option to use the revised ESRS for FY 2026. To this end, to provide certainty to the market it is necessary that the DA is finalized in a timely manner.

Ryanair Dublin O ice Airside Business Park Swords County Dublin Ireland Telephone: [phone removed] Website: www.ryanair.com June 2026 Commission Delegated Regulation (EU) amending Delegated Regulation (EU) 2023/2772 as regards the simplification of certain reporting standards Ryanair welcomes the opportunity to provide feedback on the proposed amendments to the European Sustainability Reporting Standards (“ESRS”)…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Danish Chamber of Commerce welcomes the opportunity to comment on the Commissions draft revised European Sustainability Reporting Standards (ESRS). We strongly support the overall objective of simplifying sustainability reporting under the CSRD while safeguarding the purpose of providing relevant, reliable and decision-useful sustainability information.

European Commission Brussels June 3rd, 2026 [705] IDW’s comments on the Commission’s Draft Delegated Regulation amending Delegated Regulation (EU) 2023/2772 as regards the simplification of certain sustainability reporting standards (Ares(2026)4623964 and Annex) Dear Madam or Sir, We thank you for the opportunity to comment on the European Commission’s Draft Delegated Regulation amending Delegated Regulation (EU)…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Federal Association of Corporate Lawyers in Germany Comments on the Public Consultation on the European Sustainability Reporting Standards (ESRS) Revised 03 June 2026 Task Force on ESG Contact [name removed] Head of EU-Representation BUJ e.V. [email removed] Federal Association of Corporate Lawyers in Germany (BUJ e.V.) c/o ABC Workspaces | Bertha-Benz-Str.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Water Footprint Implementation submits this feedback in response to the public consultation on the draft revised ESRS, under the Omnibus I Directive. As a practice-oriented company specialising in water footprint assessment across corporate operations and supply chains, and carrying the legacy of the pioneering work of Professor Arjen Hoekstra, our concern with the draft is specific and targeted.

Position Paper of the German Confederation of the Textile and Fashion Industry (textil+mode) on the European Commission Consultation on the Revised European Sustainability Reporting Standards (ESRS) Draft Delegated Regulation amending Commission Delegated Regulation (EU) 2023/2772 as regards the revision and simplification of the European Sustainability Reporting Standards (ESRS), Reference: Ares(2026)4623964…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

BAT wishes to submit views on two aspects of the draft ESRS. First, the requirement in ESRS 1, paragraph 76 for sustainability reporting, including metric calculation, to align with the financial reporting period. In practice, a strict alignment requirement is likely to necessitate the use of proxies and estimations to bridge timing gaps, particularly for companies that publish early in the year (e.g. mid-February).

INFORME DE FIRMA, no sustituye al documento original | C.S.V. : GEN-14ec-17ef-c3e1-7e34-311e-3484-849f-ff28 | Puede verificar la integridad de este documento en la siguiente dirección: https://run.gob.es/hsblF8yLcR Ref. Ares(2026)5648096 - 03/06/2026 VICEPRESIDENCIA PRIMERA DEL GOBIERNO MINISTERIO DE ECONOMÍA, COMERCIO Y EMPRESA Mr.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Having followed the development of the work carried out by EFRAG, The European Disability Forum welcomes the fact that the Commission is retaining elements that are key regarding the social dimension of sustainability, coherent with the CSRD and particularly related to the inclusion of persons with disabilities, including the specific DR S1-11 Persons with disabilities.

BusinessEurope acknowledges the Commissions draft Delegated Act published on 8 May 2026 amending Delegated Regulation (EU) 2023/2772 as regards the simplification of certain European Sustainability Reporting Standards (ESRS). We recognize and appreciate the Commissions efforts to introduce targeted improvements to EFRAGs original work with the objective of alleviating reporting burdens on companies.

WWF strongly welcomes European Commissions decision to uphold the core outcomes of the EFRAG multi-stakeholder negotiation process. By preserving double materiality and the fair presentation principle, the EC safeguards the EUs leadership in sustainability reporting. These choices are aligned and supported by the ECB and the FRA.

Dear Sir/Madam, We welcome the opportunity to provide feedback and strongly appreciate the effort to streamline the standards. Nevertheless, we would like to highlight several areas that, in our view, could benefit from further clarification or consideration: 1.

We support many of the European Commissions proposed revisions to the ESRS. However, there are certain revisions, which we believe would benefit from either further clarification or rewording: Level of aggregation and disaggregation We have concerns about the proposed approach to aggregation/disaggregation.

1. Overall assessment of the draft The draft Simplified ESRS represents an important and necessary step towards more proportionate sustainability reporting, aligned with the direction set by the Omnibus I package.

The Clean Air Fund (CAF) is a global philanthropic organisation working to accelerate action on air pollution and its far-reaching impacts on health, climate, and sustainable development. CAF works with governments, businesses, civil society, and communities to accelerate clean air solutions.

Joint recommendations from users of sustainability data on the European Commissions revised ESRS and voluntary standard delegated acts: Eurosif the European Sustainable Investment Forum, the Principles for Responsible Investment (PRI), the Institutional Investors Group on Climate Change (IIGCC), the European Federation of Financial Analysts Societies (EFFAS), and the Dutch Federation of Pension Funds…

Main points raised by L'Afep (Large French Companies' Association) and MEDEF (French Business Org) Anticipated financial effects: The introduction of reliefs without limiting their use over time is positive with respect to the alignment with the IFRS and given the methodological difficulties regarding several topics.

Having reviewed the Draft Delegated Act revising the ESRS, as published by the European Commission in early May 2026, we acknowledge the Commissions continued efforts to make the standards more practical and less burdensome.

A4E SUBMISSION TO THE CONSULTATION ON REVISED EUROPEAN SUSTAINABILITY REPORTING STANDARDS BRUSSELS, JUNE 2026 REVISED EUROPEAN SUSTAINABILITY REPORTING STANDARDS Airlines 4 Europe would like to provide further feedback on the draft European sustainability reporting standards (ESRS), following our response to the European Financial Reporting Advisory Group (EFRAG) consultation held in July 2025.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

In our attached letter, we observe that there is now a strong demand for stability in the EU sustainability reporting requirements and, if finalised, the revised ESRS could form part of a stable platform for undertakings to apply, enabling practice to establish over time.

Air Liquide fully supports the European Commissions objective to promote increased transparency and comparability of Sustainability information. We welcome the European Commissions intention to simplify the sustainability framework and streamline reporting.

EDF welcomes the proposed changes to sustainability reporting standards, as the current proposal strikes the right balance between the usefulness of the information for decision-making and the burden placed on those preparing the reports. EDF would like to thank the Commission for the progress made in this regard.

CDP welcomes the opportunity to provide feedback on the European Commissions draft revised European Sustainability Reporting Standards (ESRS). Please find attached our consultation response. CDP is a global non-profit that runs the worlds only independent environmental disclosure system. As the founder of environmental reporting, we believe in transparency and the power of data to drive change.

The Polish Bank Association supports the proposed revision of the European Sustainability Reporting Standards (ESRS) aimed at simplifying the reporting framework, enhancing proportionality and improving the usability of sustainability disclosures.

FSR Danish Auditors welcomes the opportunity to comment on the draft Commission Delegated Regulation amending Delegated Regulation (EU) 2023/2772 as regards the simplification of the European sustainability reporting standards (ESRS). We support the simplification objective and acknowledge the substantial work undertaken by the Commission and EFRAG. Our detailed comments are set out in the attached memorandum.

The current structure of the ESRS framework, in particular the division into ESRS 1, ESRS 2 and topic standards, is not well designed and creates unnecessary complexity for reporting undertakings. One of the main challenges is the overlap between ESRS 2 and topic standards. Information on strategies, actions, objectives and metrics is requested both in ESRS 2 and in the topic standards.

Filed in German · English published by the European Commission

We welcome the maintenance of double materiality & of most of ESRS E4 content. Our feedback: 1. AR 8 (E4-5) aggregation flexibility risks obscuring site-level signals. Compared with the 11/2025 draft, AR 8 has been materially expanded with new language relieving undertakings from listing all sites and explicitly allowing aggregation based on "similarity of sites or areas affected" and "decision-usefulness".

EuropeanIssuers welcomes the opportunity to respond to the European Commission's consultation on the revised European Sustainability Reporting Standards (ESRS). The draft contains several welcome changes, including permanent reliefs, the deletion of secondary microplastics disclosures and the inclusion of new provisions allowing the omission of commercially sensitive information in specified circumstances.

Finance Watch welcomes the opportunity to react to the draft act on the revised European sustainability reporting standards. Finance Watch supports the close alignment of the European Commissions draft act with the technical advice provided by EFRAG.

The Deutscher Steuerberaterverband e.V. (DStV) welcomes the objective of simplifying sustainability reporting for obliged undertakings. In particular, reducing the number of data points and focusing on quantitative information instead of extensive narrative reporting requirements is an improvement to the original Delegated Regulation.

Filed in German · English published by the European Commission

Observatoire de l'Immobilier Durable (OID) is an independent non-profit organization established in 2012. The OIDs contribution is part of its role in facilitating the transition of real estate stakeholders through the better integration of ESG practices, all with a view to the public interest and sustainability. The following feedback is a collective contribution from OIDs members.

according to Article AR 20 for paragraph 29 (b) outside the EU. Firstly, we respectfully consider that the European Union should not recognise or promote the use of methodologies, benchmarks or matrices for calculating living wages that have been developed outside producer countries without the effective involvement of national institutions, employers, workers and social dialogue mechanisms in those countries.

Filed in Spanish · English published by the European Commission

Airbus welcomes the simplification efforts launched within the Omnibus I package to reduce the sustainability reporting burden currently faced by companies, including through the revision of the European Sustainability Reporting Standards (ESRS).

1 DG FISMA – Corporate Reporting, Audit & Credit Rating Agencies Sven Gentner, Head of Unit Cc: Petr Wagner, Deputy Head of Unit 3 June 2026 Subject: ecoDa response to the open feedback on the final revised ESRS Dear Mr Gentner, The European Confederation of Director Associations (ecoDa) welcomes the revised ESRS framework as an important step towards simplifying sustainability reporting requirements for companies…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

positive: * simplification of DMA * reduction of qualitative datapoints * clarification impacts/baseline etc. * better readability as well as integration of AR in the Standard to be improved: * information about thresholds for materiality to be amended * S1 metrics: some definitions still leave room for interpretation and are lacking practicability * E5: still only focused on producing companies, not meaningful and…

MSCI welcomes the Commission's draft Delegated Regulation. As a global provider of sustainability ratings, data, and analytics, MSCI has a direct interest in the quality, comparability, and utility of CSRD disclosures. We support simplifying sustainability reporting. The ESRS framework generates disclosures exceeding what most investors can practically use.

The Commissions Draft ESRS Revision Still Falls Short on Simplifying Social Standards The Omnibus I legislative package establishes a clear political mandate to simplify EU sustainability regulation and strengthen European competitiveness. The ESRS delegated act must now translate this mandate into tangible and measurable simplification. However, the current draft falls short of this objective.

German insurers welcome the clarifications and amendments proposed by the European Commission. We support the clarification in ESRS 1 AR 6 for para. 19-20 and para. 21 that fair presentation is assessed at the level of the sustainability statement as a whole, and that applying the ESRS leads to fair presentation. We also support the new rules on omission of information, the clarification in ESRS E1-8 AR 19 for para.

The Danish Institute for Human Rights (the Institute) welcomes that the Commissions draft revised European Sustainability Reporting Standards (the draft) generally aligns with EFRAGs draft on several key aspects. It positively upholds the double materiality principle, which is key as it enables companies to report their sustainability impacts, financial risks and opportunities in an integrated manner.

RESPONSE Brussels, 3 June 2026 EFAMA’s RESPONSE TO EC’S CONSULTATION ON ESRS EFAMA broadly welcomes the European Commission’s proposed simplification of the European Sustainability Reporting Standards (ESRS), while preserving double materiality. As European fund and asset managers, our members occupy a critical dual role: representing both primary users and preparers of sustainability data.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

June 2026 Dr. Florian Anderhuber Deputy Director General Euromines contribution to the consultation on the revised European sustainability reporting standards Need for simplification and proportionality The Commission proposal introduces several simplification tools compared to the initial ESRS framework, such as phase-in provisions, relief mechanisms based on “undue cost and effort”, and a stronger focus on…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

SYNCRETIX supports the simplification of the ESRS, provided that simplification does not weaken the quality of sustainability data. The standards should reduce excessive formal requirements, while keeping the information that is needed to assess risks, impacts, transition costs, access to finance and the credibility of companies actions.

SLCP welcomes the opportunity to contribute to this public consultation on the revised ESRS. Please find our feedback attached, which focuses on the ESRS S2 - Workers in the value chain standard, with the aim of ensuring that reported data accurately reflects supply chain realities.

Veolia supports the European Commissions project to simultaneously streamline and facilitate compliance with EU sustainability reporting while maintaining an ambitious framework. Veolia is satisfied to see that the Double-Materiality principles remain at the core of the EUs approach to sustainability policy. Veolia also welcomes the opportunity to comment on the draft delegated act.

June 2026 1 (2) Ref. Ares(2026)5643242 - 03/06/2026 Finance Finland’s response to the European Commission consultation on the ESRS 6/2026 Finance Finland (FFI) welcomes the opportunity to respond to the European Commission’s consultation on the revised European Sustainability Reporting Standards (ESRS).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Brussels, 3 June 2026 Mr. Sven Gentner DG FISMA European Commission 1049 Brussels Belgium Dear Mr. Gentner, Public consultation on the European Commission’s draft Delegated Regulation amending Delegated Regulation (EU) 2023/2772 regarding revised European Sustainability Reporting Standards (ESRS) The European Contact Group (ECG), which brings together the six largest professional services networks in Europe (BDO…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Thank you for the opportunity to contribute to the Commissions ongoing work on sustainability reporting and SMEreadiness. On behalf of the UN Global Compact, we welcome the continued dialogue and the Commissions commitment to ensuring that reporting frameworks remain coherent, proportionate, and supportive of responsible business conduct across the EU and globally.

Department for International Affairs PGE Polska Grupa Energetyczna S.A. Warsaw, 03.06.2026 PGE Polska Grupa Energetyczna’s response to the revised European sustainability reporting standards Please find below PGE Polska Grupa Energetyczna’s comments on the revised European sustainability reporting standards (ESRS): ESRS 1 Ad.12 The ESRS says: When developing its entity-specific disclosures, the undertaking shall…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Safran fully supports the GIFAS, Afep, MEDEF and ASD responses to the consultation. The following contribution is fully in line with their responses. Main points related to issues still needed to be addressed to make ESRS the appropriate instrument for the competitiveness of European companies. Safran's contribution can be found in the attached document.

Snam, leading European gas infrastructure operator, welcomes the efforts made to reduce reporting burden even if it stems primarily from an optimisation of the requirements rather than from a real datapoints reduction. We particularly appreciated the strengthening of the top-down approach in the Double materiality assessment, the confirmation of reliefs, without any time limits, and of the omissions.

Union Professionnelle du Secteur Immobilier / Beroepsvereniging van de Vastgoedsector Feedback on the Revised European Sustainability Reporting Standards (ESRS) European Commission — Have Your Say consultation | 3 June 2026 About UPSI-BVS UPSI-BVS is the Belgian professional association of real estate developers and investors, representing approximately 60% of the office and retail markets, 40% of the residential…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Mondelez International welcomes the opportunity to respond to the European Commission's 2026 consultation on the draft final revised European Sustainability Reporting Standards (ESRS). As the market leader in chocolate, biscuits and baked snacks in Europe, with 60 manufacturing facilities, seven R&D centres, over 33,000 EU employees and 1.8 billion invested in EU manufacturing over the past five years, we have a…

We are pleased to see that the fair presentation approach has been maintained in the proposed amendments, and we are supportive that this remains the right approach to sustainability reporting. We also acknowledge the efforts made to reduce the total number of data points in the ESRS, and welcome the alignment with IFRS S1 and S2 on anticipated financial effects, as well as the flexibility introduced in relation to…

European Commission Insurance and Pension Denmark response to the European Commission’s consultation on the revised European Sustainability Reporting Standards (ESRS) Insurance & Pension Denmark is pleased to be able to provide input to the European Commission’s consultation on the revised European Sustainability Reporting Standards (ESRS). Insurance & Pension Denmark broadly supports the revised ESRS.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The PRI welcomes the European Commission and EFRAGs efforts to simplify the ESRS while preserving decision-useful disclosures for investors. It is broadly supportive of the proposal, noting it maintains most of EFRAGs technical advice and achieves simplification through editorial changes, consolidation of requirements, and a 60% reduction in datapoints, while retaining key information.

Dear Esteemed Members of European Commission, The Secretariat of the Partnership for Carbon Accounting Financials (PCAF) is grateful for the opportunity to provide input to the consultation on the Draft Act: European Sustainability Reporting Standards. Attached is our response to the consultation. Kindly reach out to us in case of any questions. Best regards [name removed]

DIE PAPIERINDUSTRIE e.V. is the association of the German pulp and paper industry. Our association represents almost the entire German paper-based value chain. Omnibus I Requires Greater Simplification: The Commissions Draft ESRS Revision Still Falls Short on Social Standards The Omnibus I legislative package establishes a clear political mandate to simplify EU sustainability regulation and strengthen European…

TIM appreciates the Commissions proposal from a methodological perspective and with regard to the revision of the materiality principle, as it is aimed at simplifying the reporting framework. Overall, this approach appears consistent with the need to strengthen the proportionality and applicability of the disclosure framework.

Forvis Mazars Group provides audit & assurance, tax, advisory and consulting services in over 100 countries and territories, with a dedication to delivering an unmatched client experience to help our clients prepare for whats next.

EFAA feedback to European Commission Public Consultation on the Revised European sustainability reporting standards 3 June 2026 The EC has launched two public consultations simultaneously: one on the revised ESRS and another on the voluntary standard.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Executive Summary Business & Science Poland (BSP), together with its member companies representing strategic sectors of the European economy, welcomes the European Commission's efforts to simplify and streamline the European Sustainability Reporting Standards (ESRS).

Dear Members of the Expert Group E03603, Please find below as well as in the additionally attached Excel document the response of econsense Forum for Sustainable Development of German Business e.V. to the European Commissions revision of the European Sustainability Reporting Standards (ESRS) as part of the current consultation process.

The European Banking Federation welcomes the opportunity to provide its feedback on draft final versions of revised sustainability reporting standards, both ESRS and voluntary standards. Given that we consider EFRAGs proposed ESRS to represent an acceptable compromise, and that a regulatory pause is necessary to allow for implementation assessment and the identification of lessons for a potential post-implementation…

We strongly support the European Commissions proposal to maintain double materiality as the basis for ESRS reporting. Double materiality is critical for business to understand their impacts on the environment and to incorporate the long-term value of the environment into an understanding of systemic risk. We strongly support the European Commissions proposal to keep the ESRS E4 Biodiversity and Ecosystems standard.

First, the TNFD Secretariat suggests edits to ensure robust materiality assessments of nature-related issues. We welcome the retained reference to LEAP within ESRS 1 (AR 16 for para 32). This maximises interoperability with the ISSB who decided in May 2026 to reference LEAP, noting it may support nature-related disclosures in accordance with the objective of IFRS S1, in the Exposure Draft expected Oct 2026.

The Estonian Chamber of Commerce and Industry supports the simplification of the European Sustainability Reporting Standards (ESRS). Undertakings that are required to report on their sustainability will benefit from simpler and more uniform standards. Reducing the number of mandatory data points by more than 60 % will result in a significant reduction of administrative burden.

Filed in Estonian · English published by the European Commission

OIC welcomes ECs modifications to EFRAGs revised TA in order to facilitating the application of ESRS by clarifying certain provisions and including additional provisions to help stakeholders having greater flexibility in reporting sustainability information.

OMV Petrom welcomes the opportunity to provide feedback on the delegated regulation concerning the adoption of the revised European Sustainability Reporting Standards (ESRS). We appreciate the Commissions efforts to simplify and streamline sustainability reporting requirements while maintaining the core policy objectives of the Corporate Sustainability Reporting Directive.

We welcome the Commissions proposal of Delegated Regulation implementing revised European Sustainability Reporting Standards. They constitute a far-reaching simplification in comparison to the first set of ESRS. However, we would like to propose several changes that would further streamline the application of ESRS and improve the revised text. our proposes are in attached file below.

Assogestioni welcomes the European Commissions efforts to simplify and streamline the ESRS with the objective of making sustainability reporting more proportionate, operational and easier to apply. However, simplification should not come at the expense of the core purpose of the ESRS framework, ensuring the availability of clear, relevant, reliable, comparable, traceable and decision-useful sustainability…

Dear Sir/Madam, Please find attached the FEA's response to the consultation on the revised ESRS. The FEA represents the CFOs of the listed companies co-signing this letter. We value the opportunity to contribute and remain available to share our implementation experience.

Overall, the Commission's revised draft represents a genuine and meaningful improvement over the November 2025 EFRAG technical advice. Within the revised ESRSs, those concerning microplastics and Substances of Concern (SoCs) are of particular interest to the plastics manufacturing industry represented by Plastics Europe. We support the deletion of text on secondary microplastics from the ESRS E2 Pollution.

We welcome the increased clarity and internal coherence of the current draft on adequate wages, which represents an improvement on the previous version. We are particularly encouraged by the retention of the adequate wages reference in S1-9 (AR 20, paragraph 29), the grounding of the adequacy assessment in ILO principles, and the removal of language implying that statutory minimum wages can be used as a benchmark…

Comments on the European Commission’s proposals to simplify certain sustainability reporting standards1 and to establish a sustainability reporting standard for voluntary use Eumedion, representing the interests of institutional investors with more than €8 trillion assets under management, welcomes the European Commission’s proposal to simplify the European Sustainability Reporting Standards (ESRS) without…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Round Table for Industry (ERT) strongly supports the objective of revising the European Sustainability Reporting Standards (ESRS) Set 1 to materially reduce the reporting burden for European companies while addressing the needs of relevant stakeholders. The first two years of ESRS implementation have clearly demonstrated that the current framework is excessively complex and disproportionately granular.

Globally online with Gifas, Afep-MEDEF and EU association ASD responses. Main points for Thales : Fair presentation: several changes to the text bringing improvements (new §21 AR4 & 6) but this is a new concept whose implications for auditing are not clear and could contradict the simplifications objective. So we are opposed to the introduction of this concept.

Position on Draft Simplified European Sustainability Reporting Standards (ESRS) Simplify reporting standards and reduce the administrative burden on businesses ZVEI welcomes the European Commission’s initiative to simplify the European Sustainability Reporting Standards (ESRS) under the Corporate Sustainability Reporting Directive (CSRD).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Forética welcomes the effort to simplify the ESRS and the intention to reduce administrative burdens for companies, particularly in a context where many organisations are still consolidating their internal capabilities for sustainability reporting, controls, and information management.

GIFAS (the French aerospace sector) contribution: In line with Afep-MEDEF and EU association ASD responses. Main points : Fair presentation: several changes to the text bringing improvements (new §21 AR4 & 6) but this is a new concept whose implications for auditing are not clear and could contradict the simplifications objective. So we are opposed to the introduction of this concept.

On behalf of the European Federation of Pharmaceutical Industries and Associations (EFPIA), we welcome the opportunity to contribute to the call for feedback on the Revised European sustainability reporting standards.

VCI, the German Chemical Industry Association, supports the European Commission's efforts to reduce burdens and simplify processes and acknowledges the European Commissions draft Delegated Acts published on 8 May 2026 amending Delegated Regulation (EU) 2023/2772 as regards the simplification of certain European Sustainability Reporting Standards (ESRS).

The ANC very much welcomes the proposed developments of the ESRS, as the current proposal based on the good EFRAGs technical advice achieves an overall balance between decision usefulness and preparers burden. However, six key points require further comment: 1.

The European Commission has largely upheld the technical advice from EFRAG, which delivered a balanced framework through rigorous expert process and consultation with preparers and users of corporate sustainability information.

Norsk Hydro (Hydro) is the largest aluminium producer in Europe with a longstanding commitment to sustainability. In this context, the revised European Sustainability Reporting Standards (ESRS) are highly relevant for Hydro, as they underpin our approach to transparent and comparable ESG reporting.

What We Welcome GDR architecture (GDR-P/A/M/T): Consolidating policy, action, metric, and target requirements from 11 topical standards into four cross-cutting General Disclosure Requirements in ESRS 2 eliminates major duplication and is the most impactful structural improvement. Top-down materiality codified (para.

IIGCC welcomes the opportunity to respond to the European Commission's consultation on the revision of the European Sustainability Reporting Standards (ESRS). We commend EFRAG's efforts to simplify the requirements while maintaining their integrity and the Commissions decision to preserve much of EFRAGs work.

Environmental Defense Fund Europe broadly supports the objective of making sustainability reporting under the revised ESRS more focused, proportionate and decision-useful, while stressing that simplification must not undermine the core purpose of the CSRD: improving transparency, enabling efficient capital allocation and supporting the EUs transition to a resilient, climateneutral economy.

We welcome the revised and clarified European Sustainability Reporting Standards (ESRS) as they reduce the total number of datapoints, clarify the double materiality assessment, while also providing robust and harmonized sustainability data.

BDEW welcomes the opportunity to provide feedback on the European Commissions draft amendments to the European Sustainability Reporting Standards. BDEW, the German Association of Energy and Water Industries, representing more than 2,000 companies in the electricity, gas, heating, water and wastewater sectors. ITS members include local, municipal, regional and national companies.

Filed in German · English published by the European Commission

Feedback on the draft Delegated Regulation amending the European Sustainability Reporting Standards Submitted by Datamaran via the European Commission’s “Have Your Say” feedback period · Subject: the double materiality assessment We welcome the opportunity to provide feedback on the draft Delegated Regulation.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The German Banking Industry Committee (GBIC) welcomes the European Commissions efforts to revise the European Sustainability Reporting Standards (ESRS) to create a more targeted, proportionate and operationally feasible framework under the Corporate Sustainability Reporting Directive (CSRD). Compared with earlier drafts, the revised text introduces clear improvements, including better drafting, and clarifications.

The Deutsches Rechnungslegungs Standards Committee (DRSC) is the national standard setter in the area of group financial reporting in Germany. The organisation was established on 17 March 1998 as an independent and registered not-for-profit association by German Industry and is domiciled in Berlin.

We appreciate the opportunity to comment on the proposed revisions to the European Sustainability Reporting Standards (ESRS) that respond to early implementation experience under the Corporate Sustainability Reporting Directive (CSRD) and to address concerns raised by preparers and users regarding complexity, operability and reporting burden.

European Commission Public Consultation Ref. Ares(2026)4623964 Ref. Ares(2026)5630939 - 03/06/2026 Simplified ESRS – Fluidra contribution to the public consultation Fluidra welcomes the European Commission’s initiative to simplify the European Sustainability Reporting Standards (ESRS) and reduce unnecessary reporting burdens while preserving the objective of providing decision-useful sustainability information.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ESRS 2 - We would also like to state that the continued requirement to disclose both quantitative and qualitative information on the anticipated financial effect is justified and necessary. This is important information for investors and helps to create a meaningful connection between the sustainability report and the financial report.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Footprint Etica, as an Italian association of 41 member companies generating an aggregate turnover of EUR 109 billion, employing 164 people and operating in ten different sectors, welcomes the work carried out in recent months by the European Commission, in terms of reducing the bureaucratic burden on companies and clarifying the specific functions and processes of the new sustainability reporting under the CSRD.

Filed in Italian · English published by the European Commission

We strongly support the alignment of ESRS E4-5 with the core components of the state of nature (AR10 for paragraph 2), the maintenance of double materiality (ESRS 1, 3.1) and the need to disclose the rationale for climate transition plans that are not aligned with 1.5 degree goals (ESRS E1-1).

Our response welcomes the maintaining of impact and financial materiality on equal footing and notes the continued interoperability with GRI. - MAINTAINING IMPACT AND FINANCIAL MATERIALITY ON EQUAL FOOTING: We welcome that the Commission kept impact and financial materiality on equal footing and maintained double materiality, as anchored in the CSRD.

CNV Internationaal is the development and international cooperation organization of the National Federation of Christian Trade Unions in the Netherlands (CNV). Founded in 1967 it collaborates with trade unions and partner organizations across Africa Asia and Latin America to promote decent work labor rights and social dialogue.

Oesterreichs Energie begrüßt die vorgeschlagenen Überarbeitungen der ESRS. Sie stellen einen wichtigen Schritt dar, um die Praktikabilität und Akzeptanz der Nachhaltigkeitsberichterstattung zu erhöhen, insbesondere durch die deutliche Reduktion der Datenpunkte um ca.

As an early adopter of sustainability reporting and voluntary ESRS alignment, EnBW welcomes the revision of the European Sustainability Reporting Standards (ESRS). However, we emphasise that the key priority must be long-term stability and legal certainty, ensuring that remaining inconsistencies are addressed comprehensively now in order to avoid uncertainties in the future.

Danske Slagterier welcomes the European Commissions efforts to simplify and streamline the sustainability reporting framework through the revised ESRS and the Sustainability Reporting Standard for voluntary use. In particular, the reduction of datapoints, improved clarity, and strengthened focus on materiality are important steps towards a more proportionate and effective reporting regime.

ISEAL supports ambitious sustainability systems and their partners to tackle the worlds most pressing challenges. We are a recognised thought-leader in defining and advancing good practices for sustainability systems like third-party standards of conduct. ISEAL supports effective and impactful sustainability policy and advocates for a smart mix of voluntary and mandatory action to drive sustainability impacts.