Simplification of certain sustainability reporting standards

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 competitiveness. The ESRS delegated act must now translate this mandate into tangible and measurable simplification.

European railway sector, represented by CER welcomes the opportunity to comment on the European Sustainability Reporting Standards. Please find attached CERs consolidated response to the public consultation on the revised European Sustainability Reporting Standards, setting out our comments on the draft Delegated Act amending Delegated Regulation (EU) 2023/2772.

The adoption of the revised European Sustainability Reporting Standards is an important step in simplifying sustainability reporting in the EU. Companies that will still be required to report sustainability information will benefit from simpler and more streamlined standards.

Filed in Italian · English published by the European Commission

Ref:PAG/19/2026 3 June 2026 Japanese Bankers Association JBA comments on the draft revised European Sustainability Reporting Standards (ESRS) Dear European Commission: The Japanese Bankers Association (JBA) appreciates the opportunity to provide its comments on the draft revised European Sustainability Reporting Standards (ESRS), released on 6 May 2026.

The Ethos Foundation currently represents over 250 Swiss pension funds, insuring more than 2.3 million people in Switzerland and managing assets totalling over CHF 400 billion. We support the EUs objective of reducing reporting burden while preserving high-quality sustainability-related information for capital markets and other stakeholders but identified four areas of concern in the proposed delegated regulation…

We appreciate the opportunity to comment on the proposal of a Delegated Act amending Delegated Regulation (EU) 2023/2772 as regards the simplification of certain European Sustainability Reporting Standards (ESRS).

ENGIE welcomes the opportunity to respond to this consultation and appreciates the improvements introduced in the Commissions draft delegated act. While the proposal usefully clarifies several provisions and simplifies certain requirements, a limited number of important shortcomings remain to be addressed, includingbut not limited tothe provisions on anticipated financial effects.

Fortum appreciates the work done by EFRAG and the Commission to simplify the European Sustainability Reporting Standards (ESRS). We support the aim to cut administrative burden for EU businesses while preserving the quality of sustainability disclosures. Fortum mainly supports the draft final versions, however, we still see a need for some clarifications and amendments. Please find our feedback attached.

We appreciate the opportunity to provide feedback on the revised European sustainability reporting standards. Our feedback seeks to clarify whether our U.S.-based parent company falls within the scope of the EU CSRD as a third-country parent undertaking under Article 40a.

I am submitting this comment in personal capacity as a Talent Development Leader, in support of a co-authored position note on the draft revised European Sustainability Reporting Standards (Ref. Ares(2026)4623964). This submission is co-authored with Jessica Kay Bensch (Founder and Convener, Vanguard Voices) and Sanghamitra (Mitra) Saha (Compliance and Risk Professional, in personal capacity).

Disclosure Requirement S1-9 Adequate Wages We consider that the principles, methodology and conventions of the International Labour Organisation (ILO) constitute the legitimate and universally applicable international framework underpinning compliance with the payment of adequate wages.

Filed in Spanish · English published by the European Commission

The Dutch National Institute for Public Health and the Environment (RIVM) expresses its concerns regarding the proposed revision of the ESRS. The main concerns relate to missed opportunities for essential data gathering, both in its breadth and its quality, due to: 1) an undermined double-materiality assessment, with the top-down approach leaving blind spots uncovered and lacking granularity, 2) reliefs with regards…

Dear Sir or Madam, MHA plc, an independent member of Baker Tilly International, welcomes the opportunity to provide feedback in response to the European Commissions public consultation on the draft revised European Sustainability Reporting Standards (ESRS) published as part of the Commissions broader sustainability reporting simplification agenda under the Omnibus I package.

UHY ECA Audyt Sp. z o.o. Sp.k Połczyńska 31A 01-377 Warszawa Phone [phone removed] Email [email removed] Web www.uhy-pl.com 1. The Perspective of an Independent Verifier of Sustainability Reports The CSRD has mandated limited assurance reviews of sustainability reports.

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

It is regrettable that the ESRS are being revised in the absence of substantial evidence that they are too burdensome for companies. The CSRD foresees an evaluation of the ESRS at least every three years; however, the process of revision started before many companies had published their first sustainability statements, thus there was no serious basis to evaluate the effectiveness of the Set 1 ESRS.

LES ATELIERS DU FUTUR - June 2, 2026 The draft Commission Delegated Regulation amending Regulation (EU) 2023/2772 revises the ESRS under Omnibus I. It broadly follows EFRAGs December 2025 technical advice, but adds amendments five of which substantially weaken the climate standard. The ECB, EBA, EIOPA and ESMA warned in February 2026 that the accumulated relaxations risk degrading quantitative data quality.

The Climate Leadership Coalition (CLC) is pleased to comment on the two draft Delegated Regulations that together establish the revised European Sustainability Reporting Standards (revised ESRS) and the sustainability reporting standard for voluntary use (the voluntary standard).

As our response exceeds 4,000 characters, we have attached the full version as a separate file. Response of the Lithuanian Responsible Business Association (LAVA) to the European Commissions Consultation on the Revised European Sustainability Reporting Standards (ESRS) PART III OF III Conclusion LAVA welcomes the European Commissions efforts to make the ESRS more proportionate and operationally feasible.

CTT welcomes the European Commissions initiative to revise and simplify the ESRS and would like to highlight the following points based on implementation experience. On anticipated financial effects (AFE), we recommend limiting disclosures to qualitative information until robust and standardised quantitative methodologies are available, as this would better preserve comparability, completeness and auditability.

As our response exceeds 4,000 characters, we have attached the full version as a separate file. Response of the Lithuanian Responsible Business Association (LAVA) to the European Commissions Consultation on the Revised European Sustainability Reporting Standards (ESRS) 3. PART II OF III.

As our response exceeds 4,000 characters, we have attached the full version as a separate file. Response of the Lithuanian Responsible Business Association (LAVA) to the European Commissions Consultation on the Revised European Sustainability Reporting Standards (ESRS) PART I OF III This document sets out the views of the Lithuanian Responsible Business Association (LAVA) on the draft revised European Sustainability…

The United Nations Environment Programme World Conservation Monitoring Centre (UNEP-WCMC) is a global centre of excellence on biodiversity and natures contribution to society and the economy. We work at the interface of science, policy and practice to tackle the global crises facing nature and support the transition to a sustainable future for people and the planet.

Global Standard gGmbH welcomes the opportunity to provide feedback on the updated drafts of the European Sustainability Reporting Standards (ESRS). As the organisation operating the Global Organic Textile Standard (GOTS), Global Standard gGmbH supports the objective of making sustainability reporting clearer, more proportionate, and more accessible for undertakings.

CEWEP Contribution to Public Consultation Revised European Sustainability Reporting Standards CEWEP (Confederation of European Waste-to-Energy Plants) is the European umbrella association representing operators of Waste-to-Energy (WtE) plants across Europe.

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

Future Up welcomes the European Commissions efforts to simplify sustainability reporting requirements and improve the usability of the ESRS and the voluntary standard for SMEs (VSME). However, from the businesses in our network we know that the main challenge does not lie in the objective of sustainability reporting or the reporting obligations itself, but in the collection, management and exchange of the underlying…

EY welcomes the initiatives led by the European Commission (EC) and EFRAG to simplify the ESRS. We focus our comments in the attached cover letter on a small number of priority areas, targeted clarifications, and longer-term considerations as follows.

amfori sees the draft ESRS as a good compromise between pragmatism and reporting value for companies. We ask for the swift adoption of the ESRS without further significant alterations. The new approach leverages the expertise developed by companies under international frameworks and brings reporting and due diligence processes closer.

R3 supports the simplification of the European Sustainability Reporting Standards (ESRS) pursued by the Omnibus package, as it improves the clarity, proportionality and usefulness of the information disclosed. However, this simplification should not be to the detriment of the purpose of the CSRD: produce relevant, reliable, comparable and material information in the sense of double materiality, useful for investors…

Filed in French · English published by the European Commission

Impact France takes note of the publication by the European Commission of its lighter proposals for non-financial reporting standards. The movement recalls that its objective is to contribute to the development of a sustainability reporting framework that is demanding but workable, designed on the basis of the realities on the ground and capable of producing reliable, comparable information that can be used by…

Filed in French · English published by the European Commission

The World Benchmarking Alliance (WBA) welcomes the opportunity to respond to this consultation on the revised European Sustainability Reporting Standards (ESRS). We strongly support retaining the living wage reference in ESRS S1-9 (AR 20, paragraph 29) as currently drafted, which defines adequate minimum wages as those providing "a decent standard of living as confirmed by a calculation in line with the ILO…

AFG welcomes the European Commission (EC)s objective to simplify the ESRS indicators. We would like to draw attention to the following points: Double materiality: As a European stakeholder, we reiterate the importance of preserving the principle of double materiality (DMA) within the ESRS framework, as maintained by the EC in the current review.

We welcome the opportunity to respond to the consultation on the Revised ESRSs. Our submission sets out a number of concerns regarding the draft Delegated Regulation. Climate-related disclosures: The EC is encouraged to align more closely with EFRAG's technical advice on climate disclosures.

SEOPAN, the Spanish Association of Infrastructure Contractors and Concessionaires, welcomes the public consultation launched by the European Commission to revise and simplify the European Sustainability Reporting Standards (ESRS). Global infrastructure companies associated to SEOPAN provide the following comments, including general observations and specific comments on individual activities

Vanguard Voices welcomes the opportunity to comment on the draft revised European Sustainability Reporting Standards (Ref. Ares(2026)4623964). This submission is co-authored by Jessica Kay Bensch (Founder and Convener, Vanguard Voices), Sanghamitra (Mitra) Saha (Compliance and Risk Professional, in personal capacity), and Brandon Springle (Talent Development Leader, in personal capacity).

The HDE sees a continued strong need to minimise the disproportionate and unclear rules on sustainability reporting. The ESRS revision offers an opportunity to effectively and sustainably relieve companies of bureaucratic requirements. This opportunity must now be seized. From the point of view of businesses, there is a need for a clear start-up signal and consistent steps to strengthen the business location.

Filed in German · English published by the European Commission

Open Supply Hub (OS Hub) is the world's largest open supply chain mapping platform, having mapped millions of production locations alongside a community of over 4,300 organizations including global brands, suppliers, civil society groups, MSIs, certification bodies, and researchers such as Amazon, WWF, the Worker Rights Consortium, and Climate TRACE.

Dutch pension funds welcome the opportunity to comment on the European Commissions draft revised ESRS Delegated Act and support efforts to enhance the coherence of the EU Sustainable Finance. In particular, we welcome that the Commission has largely remained aligned with EFRAGs technical advice. Nevertheless, several targeted improvements and clarifications remain necessary.

UECBV welcomes the European Commissions initiative to simplify the ESRS and calls for appropriate recognition of carbon removals in climate target-setting. UECBV acknowledges and welcomes several important improvements introduced by this proposal.

Eurelectric welcomes the European Commissions efforts to ensure the European Sustainability Reporting Standards remain both meaningful for investors and operable for reporting companies. We also appreciate the involvement of stakeholders, especially as our extensive representation of the power value chain is a decisive source of expertise in sustainability.

The CMA CGM Group welcomes the opportunity to contribute to the revision of the ESRS. To ensure legal certainty, methodological clarity, and alignment between the ESRS, the Renewable Energy Directive and the GHG Protocol, while playing a supporting role for the decarbonization in EU and global supply chains, we call for the ESRS to explicitly recognise mass balance mechanisms as relevant tools when calculating the…

We welcome the revised draft of the ESRS under the Omnibus I simplification package. With regard to the proposed requirement for undertakings to disclose when the targets included in their climate transition plans are not aligned with the 1.5°C objective, our comment is that the assessment of alignment between emissions reduction targets and climate transition plans would be strengthened through the development of…

Accountancy Europe welcomes the European Commissions (EC) draft delegated act with the revised European Sustainability Reporting Standards (ESRS). We appreciate that the EC made limited changes to EFRAGs technical advice as this is in line with the principles of the Better Regulation (see our February 2026 statement: https://shorturl.at/YX0PU).

We welcome the overall clarifications provided in the Draft Delegated Act on European Sustainability Reporting Standards (ESRS) for the Corporate Sustainability Reporting Directive (CSRD). To ensure a practical implementation, we would like to bring the following point to your attention: Reintroducing standardized metrics related to biodiversity and ecosystems change The Draft Delegated Act on the ESRS, in line with…

We regret that ESRS are revised without tangible evidence that they represent an excessive burden for companies. However, the CSRD provides for an evaluation of the standards “at least every three years”. However, the review was initiated even before many companies published their first sustainability statement, without an empirical basis to devalue the effectiveness of the ESRS in the first batch.

Filed in French · English published by the European Commission

Siemens believes in the importance of standardization and the development of a shared language, as intended by the EU Taxonomy Regulation and the Corporate Sustainability Reporting Directive (CSRD). We are strong supporters of advancing sustainability reporting by promoting greater accuracy, comparability and reliability.

Merck welcomes the Commissions intention to make sustainability reporting simpler and more cost-effective for companies. However, there are still several significant new or changed requirements which add administrative burden and reduce comparability to previous Sustainability Statements.

Assonime appreciates the opportunity to contribute to the European Commissions consultation on the revision of the European Sustainability Reporting Standards (ESRS). In line with our previous observations on EFRAGs technical advice, Assonime considers that three issues still require further attention.

FH welcomes that the reporting requirement on adequate wages has become more benchmark-driven, and especially that, for markets outside the EU, the assessment of wage adequacy is anchored in ILO principles for estimating a living wage. This means that multinational undertakings must go beyond statutory minimum wage standards, which in many countries do not correspond to a living wage.

The German CEO Alliance on Climate and Economy (Stiftung KlimaWirtschaft) welcomes the opportunity to contribute to the European Commissions consultation on the revised European Sustainability Reporting Standards (ESRS), including the draft delegated regulation and its annex.

The Observatorio de Responsabilidad Social Corporativa (Observatorio RSC) is concerned that several amendments introduced by the European Commission in the draft revised ESRS go beyond the technical advice provided by EFRAG and may weaken some of the core objectives of the CSRD framework.

1) Support maintaining the living wage reference in ESRS S1-9 (AR 20, paragraph 29); 2) Endorse the use of ILO principles (as agreed in the 2024 ILO Governing Body conclusions) to assess wage adequacy; 3) Highlight that minimum wages should not be treated as equivalent to adequate wages; and 4) Emphasis alignment with the CSDDD, which recognises the right to a living wage.

Please find attached the comments by Shift, which focus on the following elements: 1. Maintain the improved metric on adequate wages in S1 which is feasible for companies to implement and which will yield comparable and decision-useful information for investors and other stakeholders 2.

Investors rely on high-quality, reliable and comparable sustainability-related information to make informed investment and stewardship decisions, manage portfolio risks, fulfil fiduciary duties and allocate capital effectively. ICGN supports the objective of reducing unnecessary complexity and reporting burden.

The Chamber of Tax Consultants and Auditors (KSW) is the statutory representative body for more than 6300 tax Consultants and almost 2000 accountants and more than 4300 trainee employees in Austria. We take this opportunity to present our opinion on the amendment to Delegated Regulation (EU) 2023/2772 as regards the simplification of certain sustainability reporting standards, as set out in the attached letter.

Filed in German · English published by the European Commission

Dear Ladies & Gentlemen, On behalf of the Society for Corporate Governance and the National Association of Manufacturers (NAM), I am submitting the attached Position Paper regarding presentation flexibility to promote the operational effectiveness and usability of the ESRS. Kind regards, [name removed]

Allianz acknowledges the European Commissions continued efforts to make the standards more practical and less burdensome. We particularly welcome the new clarifications on the concept of fair presentation, which confirm its role as an overarching principle prioritising relevance and proportionality and, importantly, reaffirm that compliance with ESRS is presumed to achieve fair presentation.

Thank you for the opportunity to provide feedback on the revised European Sustainability Reporting Standards (ESRS). The American Forest Foundation (AFF) is a non-profit, mission-driven organization committed to creating meaningful climate mitigation by empowering U.S.-based small holders of forest land with accessible and high-durability interventions that both benefit their individual families and the climate.

The VÖWG welcomes the aim of the revised European Sustainability Reporting Standards (ESRS). The measures are in principle suitable for reducing the administrative burden on companies and making sustainability reporting more practical. However, the current draft shows that significant challenges remain in terms of clarity, comparability and practicality.

Filed in German · English published by the European Commission

France Assureurs welcomes the work completed by the European commission in its Exposure Drafts of the ESRS and supports the overall objective of simplification and clarification of the framework. We support the Commissions decisions not to explicitly include the ISSB proposal on the non-obscuring principle in the draft, preserving legal certainty and operational feasibility for preparers and users.

As users of ESG data, BVI members highly value the benefits of standardised sustainability reporting under the ESRS. Data reported by companies is more accurate, timely and low-cost for investors than information obtained from commercial ESG data vendors and more reliable due to the assurance requirement.

Thank you for the opportunity to provide feedback on the revision of the ESRS. Concerning AR 20 for paragraphs 29 and 30: Under existing EU legislation (RED, EED, EPBD, ..) waste heat is recognised as zero-emissions energy. However, ESRS E1 rely on the GHG Protocol, which does not reflect this approach. This creates inconsistencies in reporting, legal uncertainty, different interpretations by auditors, ...

European Metals, the European non-ferrous metals association, welcomes the simplification exercise carried out by the European Commission and the European Financial Regulatory Advisory Group (EFRAG) towards the revision of the first set of the European Sustainability Reporting Standards (ESRS).

The Spanish Meat Industries Association (ANICE) and the Meat and Meat Industries Business Federation (FECIC) welcome the initiative of the European Commission to review and simplify ESRS and thank the Commission for the opportunity to be consulted and to provide its feedback to the public consultation.

Filed in Spanish · English published by the European Commission

Dear Members of the Commission, Please find attached the REWE Groups position on the revision of the ESRS. While we generally welcome many of the proposed simplifications, we believe there is still room for further clarification. For details, please refer to the attached file. Best regards, [name removed] Group Sustainability Team

Dear Sir, Madam, The Austrian Federal Economic Chamber, Reg. No 10405322962-08, has drawn up the attached opinion on the Revised European sustainability reporting standards (ESRS) initiative. This was uploaded due to the limited number of characters in the feedback field in the Annex. Best regards, Dr [name removed], Head of Department

Filed in German · English published by the European Commission

CNCC is pleased to contribute to the European Commissions call for feedback on the draft Delegated Act on the revised European Sustainability Reporting Standards (ESRS). We wish to acknowledge the considerable work undertaken over the past year by the European Commission (EC) and EFRAG, in its capacity as technical advisor, with a view to reducing the reporting burden on companies subject to the Corporate…

Filed in French · English published by the European Commission

The Living Wage Foundation, which calculates the Real Living Wage in the UK and has a network of over 16,000 employers in the country paying at least the Real Living Wage to their workforces, would like to provide the following input on the proposed revised ESRS: - It's important that the references to 'a living wage' and 'living wage estimate' are maintained in ESRS S1-9 AR 20, para. 29.

BW2E has been highlighting, to the Belgian authorities, the inconsistency of referal to the GHG Protocol in ESRS E1. So it may discourage the use of waste heat (f.e. from waste incineration) in efficient district heating solutions that are promoted under the EU energy & climate policy. So, BW2E wants to insist on implementation of the amendment, proposed in the atached text by the BE Ministry of Environment.

Brussels, 2 June 2026 EPF Feedback - Draft Delegated Regulation on the Simplification of Sustainability Reporting Standards The European Panel Federation (EPF), representing the European wood-based panels industry, welcomes the Commission’s initiative to simplify the European Sustainability Reporting Standards (ESRS) and to improve their usability following the first phase of implementation.

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

CFDT - Confédération française démocratique du travail regrets that the ESRS are being revised in the absence of substantial evidence that they are an excessive burden on companies. The new ESRS represent an even further reduction of the revised ESRS of November 2025.The draft revised ESRS contains even more regressive elements than the EFRAG recommendations and thus undermines the objectives of the CSRD, in…

FAR welcomes the European Commissions draft delegated act on the revised European Sustainability Reporting Standards. We appreciate that only limited changes have been made to EFRAGs technical advice, which supports stability in the EU sustainability reporting framework. Although FAR notes some shortcomings, stability remains important.

We welcome the removal of any reporting obligations on secondary microplastics. This will help the goal of the revised European sustainability reporting standard in becoming simpler and more streamlined. It will help as well to avoid double reporting along the value chain.

T&E appreciates the opportunity to participate in this public consultation on the revised ESRS. T&E welcomes the retention of key principles such as double materiality, fair presentation, and the integration of sustainability due diligence considerations, which constitute the backbone of the EU sustainability reporting framework.

AXA welcomes the European Commissions initiative to enhance the clarity, flexibility and proportionality in the ESRS framework notably by (i) confirming existing reliefs, (ii) clarifying the proportionate approach to users information needs, (iii) simplifying geographical analysis in the context of the Double Materiality Analysis (DMA) and (iv) clarifying the concept of fair presentation among other examples (see…

The company welcomes the European Commissions initiative to simplify the ESRS while preserving the usefulness of sustainability reporting for decision-making. The proposed reinforcement of the materiality filter, the clarification of value chain reporting and the introduction of additional reliefs and phase-ins represent a clear step in the right direction, particularly for large multinational companies with complex…

The Danish Agriculture and Food Council (DAFC) welcomes the revised ESRS and acknowledges several important improvements. In particular, the significant reduction in datapoints is an important step towards lowering reporting complexity. The standards are also clearer and more accessible, improving their usability in practice.

As ERGaR, we welcome the consultation on the draft Delegated Act revising the European Sustainability Reporting Standards, especially ESRS E1 on climate change, decarbonisation targets and GHG emissions reporting. We particularly welcome the improved consistency on biogenic emissions, including their exclusion from Scope 1, 2 and 3 reporting when arising from combustion or biodegradation of biomass.

The German Social Insurance (DSV) would like to draw the European Commissions attention to an implementation issue that companies in Germany are facing in relation to the health and safety metrics under S1-13. The issue concerns the reporting of occupational diseases, referred to as work-related ill health within the health and safety metrics.

European Commission Rue de la Loi / Weststraat 200 I 049 Brussels Belgium Prague, June 1, 2026 Subject: Public Consultation on the draft delegated act revising the European Sustainability Reporting Standards Dears, thank you for the opportunity to share feedback on the revised European Sustainability Reporting Standards. Below you can find our comment on revised ESRS 1.

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

The huge improvements of the revised ESRS in comparison to ESRS set 1 are highly appreciated, especially with regard to readibility, structure, meaningful reliefs (e.g., ESRS 1.65 regarding the use of estimates or ESRS 1.74 regarding ac-quisitions and disposals) and simplifications in some aspects. There are nevertheless major areas for improvement and need for change.

As a partner of private sector companies, we support the retention of living wage reference in Article 20 for paragraph 29 of ESRS S1-9 (Adequate wage benchmarks) which keeps alignment with CSDDD and with ILO. In this context, we expressly endorse the use of the International Labour Organization (ILO) principles for estimating living wages, as reflected in the 2024 ILO Governing Body conclusions, as the appropriate…

CONSULTATION RESPONSE Ref. Ares(2026)5594923 - 02/06/2026 02 June 2026 Response to the Draft Revised European Sustainability Reporting Standards (ESRS) The current revision of the European Sustainability Reporting Standards (ESRS) represents a critical test of the EU's commitment to deliver meaningful burden reduction in sustainability reporting, as part of the broader effort to streamline the Corporate…

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

We welcome the opportunity to provide feedback on the revised ESRS. We support the simplification of the DMA process, in our experience this reduces the administrative burden with limited consequences on the quality of the DMA executed.

ECCBSO reply to consultation on Draft Revised ESRSs by EU Commission Status: 28 May 2026 Reference: Revised European sustainability reporting standards About the ECCBSO The European Committee of Central Balance Sheet Data Offices (ECCBSO) is a consultative body established in 1987 by a group of European National Central Banks that manage Central Balance Sheet Data Offices.

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

On page 5, it is stated that the publication of information on microplastics concerns only primary microplastics. In the delegated act on page 172, the definition of primary versus secondary microplastics is provided.

Filed in French · English published by the European Commission

We welcome the opportunity to contribute to the consultation on the revision of the European Sustainability Reporting Standards (ESRS). We support efforts to enhance the usability and proportionality of the ESRS, provided these revisions preserve the reliability and relevance of sustainability information for markets and stakeholders. Please find our recommendations in the document attached.

MBDA acknowledges the Commissions important efforts to further simplify the ESRS by reducing workload and unnecessary costs for companies. In line with the French AFEP -Medef response, and with our European association ASD and our French association GIFAS positions, some points related to CSRD issues still need to be addressed to make ESRS the appropriate instrument for the competitiveness of European companies.

Revised European sustainability reporting standards Position of the Czech Chamber of Commerce The Czech Chamber of Commerce (CZCC) welcomes the opportunity to comment on the Draft delegated regulation regarding revised European sustainability reporting standards.

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

IFRA welcomes some improvements in the draft Delegated Act revising the ESRS. In particular: - The recognition of the risk of double counting contributes to more accurate disclosures. - The clarification of the application of the double materiality assessment helps ensure that reporting focuses on decision useful information. - Improvements in definitions, e.g.

Position paper ESRS revision: Recognition of the Mass-Balance Approach for Low-Carbon Fuels June 2026 CONTEXT Armateurs de France is the professional organization representing nearly 60 French shipping companies, including SMEs, mid-sized and large companies, which operate around 1 245 vessels across various fleet segments.

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

Voluntary datapoint on anticipated financial effects: We support making Disclosure Requirement E111 voluntary, allowing companies to provide this information where it is relevant (e.g. for investors), without imposing a mandatory obligation on all undertakings.

The DGB and its member trade unions strongly oppose the proposed amendments to the ESRS in the context of the European Commission’s draft regulation. In the view of the DGB and its member trade unions, the planned adjustments do not lead to meaningful relief, but rather to a significant weakening of sustainability reporting and jeopardise the CSRD’s objective of providing transparent, comparable and reliable…

Filed in German · English published by the European Commission

Tata Consultancy Services (TCS) welcomes the European Commissions consultation on the draft revised European Sustainability Reporting Standards and appreciates the opportunity to provide its views as a sustainability advisory and solutions provider to financial institutions. Feedback on Draft Revised ESRS (Omnibus I Consultation) is provided below.

British Columbia Investment Management Ref. Corporation Ares(2026)5570269 - 02/06/2026 750 Pandora [name removed], BC V8W 0E4 CANADA BCI.ca Capital Markets and Credit Investments [phone removed] [email removed] VIA ONLINE SUBMISSION June 1, 2026 European Commission RE: Public Consultation on Revised European Sustainability Reporting Standards Dear Members of the European Commission, Thank you for the opportunity to…

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

Henkel appreciates the opportunity provided by the European Commission to contribute to the public consultation on the draft delegated act for the European Sustainability Reporting Standards (ESRS) as a preparer, and values We value the continued dialogue with stakeholders as well as the possibility to share practical insights from an implementation perspective.

It is very important that ILO wage-setting methodologies and trade union agreements are taken into account in order to lay the foundations of living wages, and NOT the Anker Institute’s methodology, which is currently used and is so decontextualised from the local realities of countries.

Filed in Spanish · English published by the European Commission

Atenor Position Summary on the Draft Delegated Act amending ESRS (May 2026) Atenor welcomes the simplification effort reflected in the Draft Delegated Act of 6 May 2026 notably the top-down DMA approach, the extended phase-ins, and the 'undue cost or effort' relief. However, structural requests remain entirely unaddressed. 1.

The CNMV welcomes the European Commissions initiative to revise the European Sustainability Reporting Standards (ESRS) Delegated Act and supports the objective of ensuring a sustainability reporting framework that is effective, proportionate, and operational.

The European Commissions efforts to simplify the ESRS are very welcome. In particular, the acknowledgement in the Delegated Act that businesses carrying out asset management activities should not be required to report information that is not relevant in relation to the investments they manage, as well as the clarification (application requirements (ARs) 17 and 37) that entities managing investments under fiduciary…

European Aluminium, on behalf of the aluminium value chain in Europe, welcomes the opportunity to provide comments on the draft revised ESRS. Our views and recommendations are presented in the attached paper. We stay at disposal for further discussion and look forward to the conclusion of the process. Thank you in advance for your consideration.

I would like to: Support maintaining the living wage reference in ESRS S1-9 (AR 20, paragraph 29); Endorse the use of ILO principles (as agreed in the 2024 ILO Governing Body conclusions) to assess wage adequacy; Highlight that minimum wages should not be treated as equivalent to adequate wages; and Emphasis alignment with the CSDDD, which recognises the right to a living wage.

The alignment of an "adequate wage" with the ILO principles for estimating living wages (S1-9 (AR 20, paragraph 29)) is a critical component of the ESRS, ensuring consistency with the CSDDD and with stakeholder expectations broadly (evident in the growing recognition of living wages in legislation, codes of conduct, and standards globally).

The Association of Issuing Bodies (AIB) welcomes the opportunity to comment on the revision of the European Sustainability Reporting Standards (ESRS) in particular on the provisions related to renewable energy reporting under AR18 for paragraph 26. AIB would like to highlight the importance of consistency between the ESRS framework and the existing EU framework for energy attribute tracking and disclosure. 1.

The BAK considers it essential that these standards are not further reduced or watered down in the subsequent legislative process. With regard to this social standard S 1 and 2, the BAK calls for the reporting requirements to be extended: the entire standard S 1 own workforce and also S 2 workers in the value chain are to be regarded as essential for all reporting companies and must be reported.

Filed in German · English published by the European Commission

The Commission makes a welcome improvement to DR E1-1 'Transition plan for climate change mitigation' by removing the reference to no or limited overshoot in the context of limiting global warming to 1.5°C in line with the Paris Agreement (see previous AR1).

Equinor welcomes the opportunity to comment on the European Commissions draft delegated act revising the European Sustainability Reporting Standards (ESRS). With more than 20 years of sustainability reporting experience, Equinor is committed to transparent, high-quality disclosures that support comparability, accountability and informed decision-making.

We appreciate the opportunity to comment on the amended ESRS, in particular ESRS 2 SBM-3 and E1-11 requirements related to current and anticipated financial effects. However, we believe that the current requirementsespecially under E1-11result in a disproportionate reporting burden compared to their decision-usefulness. Double materiality assessment already provides decision-useful information.

Eni acknowledges and appreciates the efforts made to reduce reporting burden and avoid over-reporting under the ESRS. The reduced emphasis on disaggregation and the confirmation of reliefs (without time limits) particularly the possibility to omit sensitive information in specific casesare positive steps.

As a NGO that supports workers and farmers in global value chains, we think it is essential that the living wage reference in AR 20 for paragraph 29 of ESRS S1-9 (Adequate wage benchmarks) is retained. We would like to emphasise the importance of using the ILO principles on estimating living wages, as agreed in the 2024 ILO Governing Body conclusions, as the methodology for assessing wage adequacy.

Compatibility with 1.5°C (E1-1 §12a & AR 2, E1-6 §24c & AR 17): Delete the obligation to disclose whether and how the companys targets are compatible with limiting global warming to 1.5°C and instead request an explanation of how the companys targets contribute to the objectives of the Paris Agreement.

Climate & Company supports simplification but calls for decision-useful changes as follows: GHG Emissions: We strongly recommend reinstating financial control as the mandatory baseline for GHG emissions reporting, with operational control available only where financial control proves insufficient.

As a nature risk analytics provider that has automated science-based risk analytics for biodiversity and nature, Dunya Analytics welcomes the Commission's efforts to improve the accessibility and usability of the ESRS framework.

La Poste welcomed the simplifications made to the ESRS. However, it considers that 3 points need to be amended. First of all, we do not consider it appropriate to take remedial actions into account in the double materiality analysis for the current negative impacts; La Poste considers that it would be more useful to withdraw this point in the interests of simplification or, at the very least, to clarify it.

Filed in French · English published by the European Commission

From the perspective of the ÖGB (Austrian Trade Union Federation), it is highly regrettable that the European Sustainability Reporting Standards (ESRS) are being revised without substantial evidence that they actually pose an undue burden on companies. The revision process began before many companies had even published their first sustainability reports.

CEZ Group position on ESRS consultation The CEZ Group welcomes the opportunity to take part in the ESRS revision consultation. Here are some comments and suggestions: The overall structure remains the same The framework still consists of 2 cross-cutting standards (ESRS 1 and ESRS 2) plus 10 topical E/S/G standards. Therefore, this is not a replacement of the ESRS architecture with a completely different model.

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

Embuild welcomes the ESRS revision and acknowledges EFRAG's simplification efforts. However, it stresses that the construction sector's structural specificities dispersed and temporary sites, cascading subcontracting, short project timelines, and dependence on clients for design are not adequately reflected in the current proposal.

Generation Investment Management LLP (Generation) is a sustainable investment manager founded in 2004 and headquartered in London. We invest in listed and private equity globally. Our Just Climate strategy is dedicated to scaling solutions for the highest-emitting, most off-track sectors of the economy through climate-led investing. Total assets under management are USD 24.7 billion as at 31 March 2026.

Warsaw, 1 June 2026 ORLEN's position regarding the Commission’s draft Delegated Act – simplified European Sustainability Reporting Standards (ESRS) ORLEN welcomes the Commission’s efforts to address the issues identified in EFRAG's technical advice from December 2025.

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

Thank you for the opportunity to share feedback on the revised European Sustainability Reporting Standards. TKM Grupp AS is a Nasdaq Tallinn listed retail and trade group operating across the Baltic region. As a reporting undertaking subject to the Corporate Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting Standards (ESRS), we welcome the opportunity to provide practical…

As the Italian National Promotional Institution and one of the largest Italian financial institutions disclosing information according to the Corporate Sustainability Reporting Directive, CDP welcomes Commission efforts to simplify the European Sustainability Reporting Standards (ESRS). In this context, we share the following recommendations.

The DGRV Deutscher Genossenschafts- und Raiffeisenverband e.V. (German Cooperatives and Raiffeisen Association) is the leading audit association of rural and commercial cooperatives in goods and services and cooperative banks. Around 5,100 cooperatives with around 990.000 employees and 20 million members are organised through the DGRV. Sustainability has always been embedded in the cooperative sector.

Filed in German · English published by the European Commission

Lubin, 1 czerwca 2026 r. KGHM Polska Miedź Spółka Akcyjna z siedzibą w Lubinie Komisja Europejska 59-301 Lubin ul. M. Skłodowskiej-Curie 48 tel.: [phone removed] fax: [phone removed] www.kghm.com NIP 6920000013 REGON 390021764 BDO 000006528 Członkowie Zarządu KGHM POLSKA MIEDŹ S.A.: Remigiusz Paszkiewicz Prezes Zarządu [name removed] Zarządu ds. Rozwoju Piotr Krzyżewski Wiceprezes Zarządu ds.

Filed in Polish · English published by the European Commission

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

Covéa supports the proposed DA on the revised ESRS, which strikes an appropriate balance between the need to simplify and reduce the reporting burden, and the will to maintain a consistent and ambitious sustainability framework.

As only a maximum of 4000 characters of feedback is allowed here and we have much more to say, please see our comments in the annex. Since feedback here is limited to a maximum of 4.000 characters and we have much more to say, please read the attachment for our statement.

Filed in German · English published by the European Commission

Eurosif welcomes that the European Commissions (EC) draft ESRS delegated act remains broadly aligned with EFRAGs final advice on simplified standards. However, we see remaining gaps that risk undermining the reliability and comparability of ESRS reports.

EuPC welcomes the European Commission's proposal for the revised European Sustainability Reporting Standards (ESRS), and in particular the decision not to include the reporting of secondary microplastics in the revised framework. As EuPC already highlighted in its response to EFRAG's public consultation, disclosing secondary microplastics does not currently yield meaningful environmental benefits.

CEVA Logistics welcomes the simplification of sustainability reporting in the EU and the revision of the European Sustainability Reporting Standards (ESRS) to reduce the burden on businesses while preserving the main objective of reporting sustainable information. This is also a relevant opportunity to define a reporting methodology applicable to the transport sector.

Turismo de Portugal, I.P. submits as an annex the document containing its technical comments in the context of the public consultation on the draft revised European sustainability reporting standards. The comments submitted reflect the perspective of Turismo de Portugal, I.P. as a public body with experience in monitoring the sustainable transition of the tourism sector and developing tools to support ESG reporting.

Filed in Portuguese · English published by the European Commission

At L'Occitane en Provence, we support maintaining the reference to a living wage benchmark rather than minimum wage, under Article 20 and paragraph 29 of ESRS S1-9 (Adequate Wage Benchmarks), as this approach is more closely aligned with our sustainability commitments and core values.

Intesa Sanpaolo welcomes the European Commissions initiative to revise and simplify the European Sustainability Reporting Standards (ESRS), reflected in the revised standards published on 6 May 2026. This initiative represents an important step towards enhancing the usability, proportionality and overall coherence of the EU sustainability reporting framework, while preserving the transparency objectives underpinning…

This contribution is jointly submitted by the Fair Trade Advocacy Office, Fairtrade International, and the World Fair Trade Organization-Europe. Please find our full submission uploaded as a PDF. Summary of recommendations: 1. ESRS S1-9 (Adequate wages): Maintain the recommendation by EFRAG to align the definition with living wages as agreed by the ILO, to ensure coherence with the CSDDD. 2.

ANIA, the Italian Insurance Association, fully supports the process of simplification of sustainability reporting, initiated by the European Commission with the Omnibus I package. In this vein, we welcome the simplification of the European Sustainability Reporting Standards (ESRS), that should be effective and reduce the reporting burden for the insurance sector, both as preparers and as users of sustainability…

POSITION PAPER ON THE DRAFT REVISED EUROPEAN SUSTAINABILITY REPORTING STANDARDS ESRS 2: Disclosure Requirement SBM-3 – Interaction of material impacts risks and opportunities with strategy and business model, and financial effects We welcome the European Commission’s efforts to simplify the European Sustainability Reporting Standards (ESRS) and to reduce administrative burden while maintaining decision-relevant…

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

ESBG supports the implementation of the ESRS and the adoption of a voluntary standard. We welcome the Commissions decision not to reopen fundamental technical aspects of the ESRS and to introduce targeted policy guardrails, while stressing the need for clarifications to ensure simplification, legal certainty and alignment with wider EU requirements.

On the alignment with international standards on Business and Human Rights We welcome the fact that the EU ESRS is closely aligned with international standards on human rights due diligence, including the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises, as well as the Corporate Sustainability Due Diligence Directive (CSDDD).

We have become familiar with the simplified ESRS project, in which we appreciate both the new, more structured layout (AR references directly under each section) and the elimination of repetitions, duplication of information.

Finnwatch response to the European Commission 29.5.2026 Finnwatch response to the European Commission consultation on the revision of the European sustainability reporting standards ESRS E1 (climate disclosures) While we welcome that the E1 standard on climate-related disclosures has maintained sufficient coverage of climate related sustainability issues, we would like to point out few changes that should be…

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

Jernkontoret, the Swedish iron and steel producers association, submits comments regarding E2-5 Substances of Concern (SoC) and Substances of Very High Concern (SVHC). 1. Jernkontoret supports limiting the SoC reporting to the chemical sector as well as adapting the terminology to REACH, thus making the datapoints more logical and possible to report. 2.

A2A Life Company welcomes the European Commission's initiative to revise the European Sustainability Reporting Standards (ESRS) and appreciates the opportunity to contribute to this consultation. As the leading Italian multi-utility, A2A is deeply committed to the energy transition: under its 20242035 Strategic Plan, the Group will invest 23 billion in clean energy and circular economy, with 78% of planned capex…

GHG Emissions: We strongly recommend reinstating financial control as the mandatory baseline for GHG emissions reporting, with operational control available only where financial control proves insufficient. Asset Managers: We call for the removal of the new exemption excluding client-managed investments from sustainability reporting scope.

28 May 2026 Dear Sir/Madam, Feedback on Revised European Sustainability Reporting Standards (“ESRS”) Temasek welcomes the opportunity to review the revised ESRS and to provide further comments following our earlier submission. We appreciate the efforts by the European Commission and EFRAG to incorporate stakeholder feedback.

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

BETTER FINANCE supports efforts to simplify sustainability reporting requirements and recognises the objective of ensuring that reporting frameworks remain proportionate and operationally feasible. Simplification can contribute to the competitiveness of European businesses and reduce unnecessary administrative burdens.

SaveOCEAN welcomes the Commission's effort to make the ESRS framework more usable, but writes to flag a specific, correctable gap: in its current form, the revised ESRS removes the only disclosure obligation that would have produced meaningful corporate data on the dominant source of marine plastic pollution. We urge the Commission to amend the draft before adoption. 1.

The draft simplified ESRS constitute a significant improvement compared to the original ESRS, and will help simplify, clarify and streamline the contents of Sustainability Statements. We however have two key comments. 1.

Please see the attached file with the complete submission response. We support the European Unions objective of reducing reporting burden while preserving high-quality sustainability-related information for capital markets and other stakeholders.

Stellungnahme zum „Entwurf eines delegierten Rechtsakts zur Überarbeitung der Europäischen Standards für die Nachhaltigkeitsberichterstattung („amended ESRS“)" Wir haben den Entwurf des delegierten Rechtsakts zur Überarbeitung der Europäischen Standards für die Nachhaltigkeitsberichterstattung („amended ESRS“) eingehend geprüft.

Filed in German · English published by the European Commission

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

Platform Living Wage Financials is an alliance of 22 financial institutions encouraging and monitoring investee companies to enable living wages and incomes in their global supply chains, representing over 7 trillion of assets under management and advice. Decision-useful information on adequate wages is of key importance to investors.

As investors integrating environmental data into portfolio construction, we write to highlight an unintended consequence of the current ESRS framework: a decline in corporate disclosure of water withdrawal and waste generation metrics. We urge the Commission to introduce minimum mandatory disclosure requirements for these indicators, regardless of company-level materiality assessments.

1. ESRS 1 – General Requirements. 9.2. Direct and indirect connectivity with financial statements, including consistency of assumptions It is said that data and assumptions used in preparing the sustainability statement shall, to the extent possible, be consistent with the corresponding data and assumptions used in preparing the financial statements.

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

Sycomore AM welcomes that the European Commissions (EC) draft ESRS delegated act remains broadly aligned with EFRAGs final advice on simplified standards. However, we see remaining gaps that risk undermining the reliability and comparability of ESRS reports.

We welcome the introduction of the value chain cap as an important and necessary step to limit disproportionate sustainability data requests within value chains and to reduce administrative burden on smaller companies. As already highlighted in our feedback to the "Value Cap" consultation, practical feasibility and proportionalityparticularly for SMEsare essential for successful implementation.

I express my views on five aspects of the draft European Sustainability Indicators (ESRS): 1. Changes to sustainability indicators were decided too early, as many companies, obliged to publish an environmental and social balance sheet, still have to prepare their own sustainability balance sheets.

Filed in Italian · English published by the European Commission

The proposal for simplified ESRS standards does not bring substantive simplification or relief for existing sustainability reporting entities. In the context of the proposed new ESRS standards, we still see a significant administrative burden on the business organization, as well as additional challenges in meeting regulatory requirements related to the implementation of due diligence across the value chain…

Concerns: Climate-related disclosures The EU Commission should maintain financial control as the mandatory baseline, with operational control as a mandatory alternative if reporting on the basis of financial control is insufficient, as per EFRAG technical advice. Climate Transition Plans climate transition plans not aligned with the Paris objective are not credible climate transition plans.

PIU welcomes the objective of the consultation to simplify and clarify the ESRS standards while preserving their consistency with the objectives of the CSRD and ensuring the proportionality and usefulness of sustainability reporting. Overall, the proposed changes represent an important step towards making the reporting framework more practical and workable for reporting entities and users of disclosed information.

AECA welcomes the draft simplified ESRS, highlighting the 61 % reduction in mandatory data points and the balance achieved between information quality and less administrative burden. It is recognised that new flexibilities facilitate the adaptation of businesses without compromising the objectives of the Green Deal.

Filed in Spanish · English published by the European Commission

MAP360 feedback on the Annexes to the Delegated Regulation amending (EU) 2023/2772 (Ref. Ares(2026)4623964). 1. GENERAL DISCLOSURE TOPICS EFRAG implementation guidance: its legal status, applicability and authority should be set out explicitly, to avoid divergent interpretation by reporters, consultants and auditors.

While the spirit of the initiative to identify a compromise aimed at reducing bureaucracy and safeguarding the benefits of the original regulatory framework is appreciated, it is believed that the solution does not lie in a trade-off between effectiveness and simplification: the risk that the effectiveness of the entire regulatory system will collapse is too high.

The ETUC regrets that the ESRS are being revised in the absence of substantial evidence that they are too burdensome for companies. The CSRD foresees an evaluation of the ESRS at least every three years; however, the process of revision started before many companies had published their first sustainability statements, thus there was no serious basis to evaluate the effectiveness of the Set 1 ESRS.

Many thanks for the opportunity to provide feedback on the revised European sustainability reporting standards. There is an element that has bothered me right from the start which seems to be grossly overlooked. That is the mandatory E-S-G structure. Firstly, this structure often does not represent the structure or key areas of individual sustainability strategies of companies.

## Executive Summary The [EU Latin Business Forum](https://eulatinbusinessforum.eu?utm_source=chatgpt.com) statement examines the revision of the European Sustainability Reporting Standards (ESRS) under the European Commissions Omnibus simplification agenda.

It is regrettable that the ESRS are being revised in the absence of substantial evidence that they are too burdensome for companies. The CSRD foresees an evaluation of the ESRS at least every three years; however, the process of revision started before many companies had published their first sustainability statements, thus there was no serious basis to evaluate the effectiveness of the Set 1 ESRS.

TorchOil Energy FZC submits this feedback in response to the public consultation on the draft delegated act revising the European Sustainability Reporting Standards (ESRS), published 6 May 2026 under the Omnibus I Directive (Directive (EU) 2026/470). TorchOil Energy FZC is an ISCC EU-Certified B100 Biodiesel Trading Platform established in the United Arab Emirates in November 2024.

Feedback on the Revised European Sustainability Reporting Standards (ESRS) Submitted by Professor Belén Olmos Giupponi (Middlesex University London) and Professor Hannes Hofmeister (University of Bolzano) We welcome the European Commissions initiative to revise and simplify the European Sustainability Reporting Standards (ESRS).

We support the simplification objective. The datapoint reduction and clarified materiality filter are constructive. However, seven provisions risk eroding the comparability of the resulting statements. From our benchmark pool of 638 European CSRD reports (FY 2025), 27 percent already contain no Scope data and 76 percent report static values without prior-year comparison; several proposed simplifications would widen…

We welcome the opportunity to contribute to this consultation on the revision of the European Sustainability Reporting Standards (ESRS). As a global non-profit network supporting over 10,000 companies committed to using business as a force for good, B Labs standards aim to help companies measure, manage, and transparently communicate their social and environmental performance through independently verified systems.

Dear Sir/Madam, Thank you for the opportunity to provide feedback. As an employee of Systain, I advise large German companies to implement sustainability. The definition of the value chain and the scope of the commitments remain controversial in companies.

Filed in German · English published by the European Commission

The Government of Japan appreciates this opportunity to submit its comment on the draft Delegated Regulation on revised European Sustainability Reporting Standards (ESRS). In this comment letter, we make the following proposals regarding N-ESRS (ESRS for nonEU groups): - To allow non-EU companies to use the sustainability report complying with IFRS Sustainability Disclosure Standards and provide N-ESRS-specific…

The proposed revisions introduce flexibility through various reliefs, but these risk undermining the quality, comparability, and usefulness of sustainability reporting. By allowing companies to omit or approximate material information, the changes are likely to increase divergence in practices while adding unnecessary complexity for both preparers and users.

Zentiva is a major European pharmaceutical manufacturer with production sites in Prague (Czech Republic) and Bucharest (Romania), delivering essential medicines to more than 100million patients across Europe each year. As a company focused on affordable, offpatent and critical medicines, we are committed to strengthening Europes health security and supply chain resilience.

Summary of TEKNIQ's Response to EU Recommendation 2025/1710 on VSME Sustainability Reporting Standard Organization Information TEKNIQ represents approximately 4,100 companies in the installation and industrial sectors with around 60,000 employees. The majority are non-listed SMEs and micro-enterprises that fall within the target group of the VSME standard.

Ensuring consistency of assurance regarding reliefs and Undue cost or effort assessments : We strongly support the simplification objectives of the Draft ESRS, particularly the formalization of Top-down materiality assessments without exhaustive identification of all potential impacts, risks, or opportunities (ESRS 1 paragraph 32 & AR 13); The use of reasonable and supportable information available without undue…

ESRS 2 SBM-3 Paragraph 29 should be incorporated with 28. It has to be clear that in what circumstances that quantitative information are not required to be reported. Now it is very confusing. Add as paragraph 28 (C) if it does not have the skills, capabilities or resources to provide that quantitative information, and delete paragraph 29.

Anticipated financial effect related questions ESRS 1, 10.3, 125 (b) all information about anticipated financial effects, . required in paragraph 27 of ESRS 2 General Disclosures and in ESRS E1-11 for their financial years prior to financial year 2027, with the exception of ESRS E1-11 paragraph 38(a)(b) and 39 (a)(b) There is no paragraph 38 (a)(b).

We very much welcome the fact that the European Commission takes on board the practical experience of companies with the existing ESRS and provides for simplifications. In our view, reducing the mandatory data points, placing greater emphasis on materiality and improving international connectivity are fundamentally in the right direction.

Filed in German · English published by the European Commission

Disclosure Requirement E1-1 Transition plan for climate change mitigation: Point 12(a) should include both greenhouse gas emission reduction targets and GHG removal targets. AR 2 for para. 12(a) (Key features description): Please include a permanent carbon removal target in point (a).