The European Commission announced the adoption of a series of “quick fix” amendments to the European Sustainability Reporting Standards (ESRS), delaying the addition of new requirements for large companies already reporting under the Corporate Sustainability Reporting Directive (CSRD), including new disclosures in areas including biodiversity, workers in the value chain, and Scope 3 emissions.
The amendments come as the EU is undergoing the process of substantially revising the CSRD, as part of the Commission’s Omnibus I package, aimed at significantly reducing the sustainability reporting and regulatory burden on companies.
The CSRD, based on the new underlying ESRS, introduced detailed reporting requirements on company impacts on the environment, human rights and social standards and sustainability-related risk. The directive took effect from the beginning of 2024 for large public-interest companies with over 500 employees, with the first reports being issued in 2025, which were to be followed by companies with more than 250 employees or €50 million in revenue in the following year, and listed SMEs one year later.
The Omnibus initiative, however, will likely remove many companies from the scope of the CSRD, with the Commission proposing to raise the threshold to companies with more than 1,000 employees – and some lawmakers aiming to raise the threshold even higher. The initiative will also likely substantially reduce the amount of information reported by companies remaining in the scope of the CSRD, with the European Financial Reporting Advisory Group (EFRAG), mandated by the Commission with developing technical advice to revise the ESRS, targeting cutting datapoints under the CSRD by approximately two-thirds.
Effectively, the new amendments will stop companies that have already started reporting in the first year, or “wave one” companies, from having to provide new disclosures that were set to have been added in the second and third years of reporting, but may not be required at all once the CSRD revision is complete.
Under the new amendments, all wave one companies will be able to delay reporting on the anticipated financial effects of certain sustainability‑related risks, initially slated for next year, for another two years.
For wave one companies with fewer than 750 employees, the new amendments also extend the ability to omit reporting on information including Scope 3 greenhouse gas emissions, biodiversity and ecosystems, own workforce, workers in the value chain, affected communities and consumers and end users through financial year 2026.
The new amendments also provide wave one companies with more than 750 employees with most of the same phase‑in provisions that currently apply to companies with up to 750 employees, with reporting on biodiversity and ecosystems, several “own workforce” topics, workers in the value chain, affected communities and consumers and end users also delayed through FY 2026, although Scope 3 emissions were not included in the list of disclosures that may be omitted by the larger companies.
For smaller companies that were set to begin reporting in 2026 and 2027, European lawmakers adopted a ‘stop-the-clock’ directive earlier this year to delay implementation of the CSRD disclosure requirements during the Omnibus process.
The Commission said that it expects its review of the ESRS to be completed by financial year 2027.
