On December 3rd, 2025, EFRAG presented to the European Commission an amended version of the ESRS in force since 2024. This new version was developed in a few months thanks to specifications from the Commission and a public consultation completed in September 2025.
Substantive work, which promises a improved version of the ESRS, lighter, more operational, and maintaining the original ambitions of the CSRD. But in concrete terms, what are the changes brought about with these new ESRS?
Why were these new ESRS created?
Before looking at the content of the new ESRS, let's recall why they are needed.
Reminder: the objectives of the CSRD
La CSRD came in a context of structuring the European economic fabric around sustainability in order to achieve the ambitions of the Green Deal.
In order to respond to the pressure of financial (banks, shareholders and investors) and business (customers, prospects and communities) clients on companies, the CSRD was created to propose a harmonized reporting framework to provide a sufficient level of information to these stakeholders. In addition, thanks to the CSRD, the information is now certified by an external body, making it possible to ensure the reliability of the information shared.
The CSRD was also created to address one of the main problems of the NFRD: to prevent these reports from becoming Greenwashing opportunities for businesses. The ESRS, supporting standards of the CSRD, ensure that companies publish information on their most important impacts and risks thanks to the concept of double materiality.
In short, the CSRD aims to ensure that European companies provide ambitious, harmonized and comparable information to all their stakeholders who need it.
Regulatory burden reduced by the Omnibus proposal
In reality, the first wave of companies that implemented CSRD encountered several challenges in its application: quantity of information to be provided, complexity of the data to be collected, auditors' requirements...
CSRD was quickly perceived as a regulatory burden, impacting the competitiveness of European businesses.
In February 2026, the European Commission submitted its proposal called “Omnibus” to simplify sustainability reporting for businesses, by refounding the CSRD, the CSDDD and the Green taxonomy.
It is in this context that EFRAG was mandated to propose a new version of its ESRS, a version that is less dense and easier to apply, while still meeting the different information needs of purchasers.
The 3 elements that are the same between the ESRS versions
These new ESRS are therefore a simplified version of ESRS Set 1, but whose main principles have been retained to ensure that the primary ambitions of the CSRD are respected:
- Conservation of the Mandatory Double Materiality Analysis
- Preservation of the 12 ESRS, and therefore topics chosen for reporting
- Conservation of the great interoperability with other international standards.
Double materiality at the heart of the exercise
Double materiality analysis is the driving force behind CSRD. This mandatory exercise invites companies to objectively sort out all the issues associated with the ESG universe by following a standardized methodology.
It is on this stage that the credibility of the entire report produced is based.
It is thanks to this step that the reader knows what the most negative impacts of the company are and that he can verify what the company is putting in place in concrete terms to limit them.
It is therefore quite natural that the analysis of double materiality remains a mandatory step in the new ESRS.
Conservation of the 12 ESRS
The ESRS Set 1 proposed an architecture in 12 SERS, divided into 2 transversal ESRS, and 10 thematic ESRS.
These 12 ESRS are kept the same in the new version of the ESRS, ensuring consistency between the two versions.
This architecture is in fact optimal because it makes it possible to distribute the information in main themes of ESG, the ones on which the clients ask for the most information.
Great interoperability with international standards
One of the major spearheads of CSRD is to limit the need to duplicate reports to suit different standards. Thus, the ESRS were built to be interoperable with the largest international standards, such as the ISSB and the GRI.
The new ESRS are also highly interoperable with these other standards., making it possible to simplify the reporting process for large companies.
The 5 changes of the new ESRS
In these new ESRS, many choices have been made to ensure that this new version is easier for businesses to implement:
- Structural changes
- Changes in the methodology of double materiality analysis
- A reduction in the quantity of information
- An introduction to the concept of Fair Representation
- More operational ESRS
Structure changes
In the new ESRS, the structure has evolved slightly: some paragraphs (DR) have disappeared, others have been combined, others have been added.
The big structural change that makes it easier to read ESRS is where ARs are located. The purpose of these Application Requirements is to guide the user by providing advice on how to prepare their information.
In ESRS Set 1, these ARs are placed in the appendix of each ESRS, requiring the user to go back and forth between the ESRS and the appendices. In the new ESRS, these AR are placed at the end of each DR, ensuring consistency and that users can take full advantage of the advice provided.
Changes in the methodology of double materiality analysis
As we have seen, the double materiality analysis is retained in the new ESRS. Nevertheless, many companies have raised the the burden of having to justify the consideration of obvious risks as material. To answer this question, EFRAG proposed an evolution of the methodology: the double materiality analysis can now be carried out for all or part via a top-down approach.
Concretely, you can now quickly identify which are the material challenges in your sector (top) and consider them material for your business (down), without justification. You should always use the bottom-up approach (starting from all the IROs to bring up the material ones for you) for IROs that are not obvious.
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Reduction in the quantity of information
One of the obvious changes in the new ESRs is the reduction in the amount of information requested. All of the so-called “voluntary” information has been removed from the repository, as well as a large part of the mandatory information.
In total, 71% of the information (datapoints) from ESRS Set 1 has been removed in this new version.
Introduction of the concept of Fair Representation
Despite the great decrease in information, these new ESRS were designed with one main objective: to ensure a balance between the need to simplify the exercise and the need for information of high quality and representative for the users of the reports. This balance is explained via the concept of Fair Representation, defined in the new ESRS.
Thus, the decrease in quantity does not lead to a loss of information quality: the information that is most useful for decision-making (internal or stakeholder) has been retained, and companies have more freedom when it comes to the most appropriate level of granularity to provide information.
Increase in operationality
One of the main feedback received by EFRAG during the various public consultations this year is that the ESRS Set 1 are too theoretical, and not very applicable in practice. Indeed, companies did not understand how to apply them in practice, and they contained too many ambiguities leading to excessive demands from auditors.
In these simplified ESRS, the rules of the game and expectations are more clearly explained, and concrete application tips are given throughout. This is for example the case of clarifications on the use of time horizons in the analysis of double materiality, or of the redundancy of information if you have a policy that covers several subjects.
Conclusion
Between consistency and smart changes, these new ESRS offer a new balance for corporate sustainability reporting. Lean reporting, concentrated on useful information for businesses and their stakeholders, and allowing companies to focus on what really matters: reducing their impact.
Do you want to identify the changes between the two versions, point by point? Receive our interactive mapping !
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FAQs
Find answers to common questions about CSRD and Kiosk
The CSRD or Corporate Sustainability Reporting Directive is the new European directive which aims to impose and better regulate corporate sustainability reports.
It makes companies more transparent, with standardized ESG reporting standards called ESRS (European Sustainability Reporting Standards)
The application of the Corporate Sustainability Reporting Directive is progressive. Here is a summary table.
| Effective year | Businesses impacted | Standard |
|---|---|---|
| 2025 (over the financial year 2024) | Listed companies with more than 500 employees | ESRS |
| 2026 (sur l’exercice 2025) | Autres grandes entreprises de plus de 1000 salariés | ESRS |
| 2026 (over the financial year 2025) | Businesses that meet two out of three criteria: | VSME |
| 2027 (over the year 2026) | SMEs listed on the stock exchange | VSME |
| 2029 (over the fiscal year 2028) | Non-European companies with at least €150M in turnover on the European market | ESRS |
Want to know when your business is impacted? Use our regulatory monitoring tool to find out.
The "omnibus" bill is a recent initiative by the European Commission aimed at reducing the scope of the CSRD directive. It proposes, in particular, to raise the application thresholds: only companies with more than 1,000 employees would be affected, compared to 250 previously.
It promotes the adoption of the VSME framework to reduce the reporting burden on SMEs and mid-cap companies.
The VSME (Voluntary Sustainability Reporting Standard) is a voluntary European standard designed to help unlisted small and medium-sized enterprises (SMEs) structure and communicate their sustainability initiatives. Developed by EFRAG, this standard offers a lighter framework compared to ESRS standards, covering ESG aspects. It allows in particular to:
- Harmonizing sustainable reporting practices in Europe
- Facilitate the response to the expectations of business partners
- Improving access to responsible financing
It aims to harmonize sustainable reporting practices, facilitate meeting the expectations of business partners, and improve access to responsible financing. Although not mandatory, adopting VSME allows SMEs to demonstrate their commitment to sustainability and anticipate future regulatory developments.
- Complete the preliminary steps for the CSRD
These steps are dual materiality analysis and gap analysis. They will help you understand the material issues, impacts, risks, and opportunities for your business. They will also allow you to create a roadmap based on what you have already achieved.
Check out our article on double materiality here.
- Compile your data and produce your indicators
Centralizing sustainability data is essential for your compliance, particularly to facilitate understanding and consistency when producing quantitative indicators.
- Produce your detailed report in XHTML format with XBRL tags
Thanks to its tagging and visualization technologies, Kiosk guarantees a very high level of consistency.
Find our article on XBRL tagging here .
- Audit your data
At the end of these steps, your sustainability report is ready to be audited by an Independent Third Party Organization (ITO).
Kiosk supports your compliance journey throughout this process. For more information on these steps, we invite you to contact our team.
CSRD compliance requires companies to:
- understanding the 12 ESRS and 82 disclosure requirements
- the collection of more than 1,000 data points
- the calculation of 50-147 quantitative indicators
- tagging 4,000 items in the final report
Kiosk is a software that allows companies to save 5 months on the preparation of their CSRD report by automating the most time-consuming steps.
- First of all, the security of your data is our priority.
- All data is stored in France, in Paris, via our French hosting provider.
- During transit, your data is encrypted in SSL/TLS from the user's browser to our servers guaranteeing the security of communications.
- Data is also encrypted at rest, both on the database and on file storage, protecting the data in the event of a leak or attempted theft.
- Kiosk's technical teams are the only ones who can access your data.
- Kiosk is in the process of ISO27001 certification.
- Our technical support is available 24/7.