Getty-Images-juststockSustainability reporting
Between political stalemate and global compatibility.
SK – 10/2025
At the end of February, the European Commission
published the two Sustainability Omnibus Acts. The goal is to conclude
negotiations in the Council and European Parliament by the end of the year.
While the Member States were able to agree on a position early on, tensions in
the Legal Affairs Committee (JURI) led to unplanned delays. If the Council and
Parliament fail to reach an agreement by the end of the year, the revision of
the European Sustainability Reporting Standards (ESRS) could also face delays.
Tensions in JURI
Divisions are particularly entrenched between
the Conservatives and the Social Democrats. Rapporteur Jörgen Warborn (EPP, SE)
is pushing for simplifications and relief for companies, while the S&D
Group has long resisted any weakening of liability rules and due diligence
obligations. A last-minute compromise was only reached in mid-October. However,
the vote in the second October plenary session failed. The path to trilogue
negotiations is now set to be cleared on 13 November. Whether the Danish
Council Presidency will still be able to conclude the dossier this year as
planned remains uncertain due to the delay.
EFRAG’s proposal to revise the ESRS
Parallel to the political discussions, the
European Financial Reporting Advisory Group (EFRAG) is working on a
comprehensive revision of the ESRS. The aim is to simplify the standards, which
also include reporting obligations on accidents at work and occupational diseases.
The draft presented in July 2025 proposes reducing the number of data points by
around 55 percent. The obligations regarding occupational diseases, which
companies find difficult or nearly impossible to meet, remain untouched. EFRAG
plans to submit its technical recommendations to the European Commission by the
end of November.
However, the proposed simplification of the
ESRS is not universally welcomed. Critics warn that such reductions could come
at the expense of comparability and transparency. The Global Reporting
Initiative (GRI) has also voiced concerns. Excessive changes to the ESRS could
jeopardise the existing interoperability between ESRS and international
frameworks.
Three standards: one goal, different paths
Currently, three frameworks shape global ESG
reporting: the European ESRS, those of the International Sustainability
Standards Board (ISSB), and the GRI Standards. While the ESRS is tailored to
the EU’s regulatory requirements, the ISSB focuses more on investors’
information needs. GRI, on the other hand, takes a broader stakeholder approach
and is established in over 100 countries.
In 2024, EFRAG and ISSB published joint
guidance on interoperability to avoid overlaps and strengthen comparability.
Likewise, EFRAG and GRI have had a cooperation agreement since late 2023 to
ensure a high degree of compatibility between their standards. However, this
fragile balance could be destabilised by a far-reaching revision of the ESRS.
Risk of misalignment
If Europe diverges too far from global
frameworks in the course of the ESRS revision, problems could arise. For
internationally active companies, this would mean having to report according to
different logics – simplified, EU-internal ESRS on one hand, and ISSB or GRI
standards for other markets on the other. This would not only increase
administrative effort but also make sustainability data less comparable – the
exact opposite of what harmonisation was meant to achieve. In 2026, the
European Commission will therefore face the challenge of further developing the
European sustainability framework so that it remains practical for companies
while keeping pace with global developments.