Introduction

The CSRD is a landscape in perpetual motion. If you've spent the last few months getting familiar with European Sustainability Reporting Standards (ESRS), the announcement of a new “simplified” or “revised” version may have caused you to break a cold sweat. Don't worry: it's not about starting all over again, but rather about a welcome development aimed at lightening the work of businesses.

Following the European Commission's “Omnibus” proposal, these new standards promise to reduce the complexity of reporting while maintaining the ambition of increased transparency. But in concrete terms, how do you make this transition without losing track?

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Who are the businesses involved and what is the timetable?

Before diving into the mechanics of standards, it is essential to check whether your company is in the sights of this specific reform. The Omnibus proposal does not concern everyone in the same way and redefines some rules of the game for large structures.

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Who are the companies that are going to use these ESRS?

The companies concerned by these simplified ESRS are those falling within the scope of the CSRD following the Omnibus proposal, i.e. businesses with more than 1,000 employees and €450m in turnover.

If you fall into this category, these revised standards will become your new bedside book. For others, in particular those preparing voluntary or smaller reports, other standards such as the VSME or the MidCap (for listed SMEs and ETIs) remain relevant options.

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When will these standards be applicable?

The schedule is precise, but offers some flexibility for forecasting. These new standards should officially be adopted by the end of the first half of 2026.

In terms of pure obligation, they will become mandatory for fiscal years starting in 2027. However, proactive businesses (“early adopters”) will be able to choose to use them as early as fiscal year 2026 (report published in 2027).

Example: I am a listed company with +2,000 employees and €500M in turnover. I used the old ESRS for my 2025 report (FY 2024) and started my 2026 report on the same basis.

→ I will use simplified ESRS for my 2028 report (FY 2027). I could already use them if I want to for my 2027 report (FY2026).

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What are the major developments between V1 and V2?

Understanding the transition requires grasping the philosophy behind these changes. It is not a revolution, but a rationalization. EFRAG and the Commission listened to feedback from the field considering the first draft (Set 1) too theoretical and sometimes redundant.

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How is the balance between simplification and quality ensured?

The key word for this revision is the”Fair Representation“. The idea is to find the right balance between simplifying the exercise and providing robust information to investors and stakeholders.

This results in a drastic reduction in requirements:

• Reducing data points : There has been a 61% drop in the requirements formulated by the term “shall”.
• Removing complex options : 100% reduction in “may” data points, which often caused more confusion than clarity.
• Flexible granularity : Businesses now have more freedom to choose the relevant level of granularity (group, country, site) for each indicator, without being forced to use a model that is too rigid.

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What are the methodological and structural changes?

Beyond the removal of certain lines, it is the structure itself that is gaining in pragmatism.

‍First, the reading structure has been improved. In the previous version (Set 1), the “Application Requirements” (AR) — these valuable guides to understand how to report — were relegated to the appendix, requiring constant back and forth. Now, they are integrated directly following each associated “Disclosure Requirement” (DR). This is a considerable time saver for CSR teams.

Second, the analysis of double materiality is evolving. Still central, its methodology is being revised to be more operational. It is now possible to adopt a “top-down” approach for part of the analysis. Instead of having to justify each exclusion with an exhaustive analysis of all possible impacts (Bottom-up), the company can start from the obvious challenges for its sector or business model without excessive justification for what is clearly irrelevant.

Find out in more detail the major evolutions between the 2 versions of the ESRS.

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How to move from the old ESRS to the new ones in concrete terms?

Have you already carried out a first CSRD report or launched your double materiality analysis on the basis of old texts? Don't panic. This work is a gold mine. Here are the steps you need to follow to transform the essay.

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Step 1: How do you filter your existing material DRs?

If you've already produced a report or analysis, you've done the hard part. Your double materiality analysis has already identified your priority themes. Having done this exercise means having already secured 70% to 90% of the content of your future “new ESRS” version report.

Don't throw anything away. The objective of this first step is to start again from your list of DRs (Disclosure Requirements) materials identified in the previous version. It is not a question of redoing the materiality analysis from scratch, but of updating the scope of the data to be collected for these same themes.

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Step 2: How do you compare standards effectively?

This is where the task may seem daunting: You must identify line by line what has disappeared, what has been merged and what has been moved. Many DRs have been simplified to reduce the reporting burden.

To avoid hours of tedious comparison, the method consists in listing the DRs of the old version versus those of the new version for the same theme, and identifying the “holes” or additions.

To save you valuable time, our teams at Kiosk have created a Datapoint to Datapoint mapping. This Excel document accurately compares the ESRS Set 1 (old version) to the Amended/Simplified version. It clearly identifies:

• Deleted data.
• The new data (“New”).
• The amended data (”Amended”).
• Requirements that remain the same (“Identical”).

It is the essential tool to instantly visualize the impact of the reform on your data collection.

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Step 3: How to reorganize your content (“The furniture kit effect”)?

Once the sorting is done, it is necessary to rebuild. Imagine going from a piece of furniture that is assembled to a piece of furniture that has to be reassembled to make a more coherent model.

In version 1 of the ESRS, the information was sometimes scattered. For example, you could talk about your CSR committee in three different places: in the governance section (G1), in the climate (E1) and in the social area (S1). With the new simplified ESRS, the logic is to centralize. Everything has to be assembled and presented only once, typically in ESRS 2 GOV-1 to GOV-4.

Your mission here is to move text and data blocks to create overall consistency, avoiding redundancies. Capitalize on what you've written, eliminate the outdated, and only write what's really new.

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Conclusion

The switch to the new ESRS is an opportunity to streamline your sustainability reporting. Fewer formal constraints, more operational logic, and a clearer structure.

Do not be left alone in the face of these regulatory texts. To accelerate your transition and secure your compliance, download our complete mapping document now or make an appointment with our experts for a personalized diagnosis.

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