Our submission, delivered to EFRAG in September 2025, provides detailed investor feedback on the latest proposed changes to European Sustainability Reporting Standards.
EFRAG’s revised ESRS drafts substantially streamline corporate reporting. The amendments simplify the double materiality assessment, cut mandatory datapoints by 57%, and remove voluntary disclosures. Definitions and reporting requirements are clarified across the standards, and targeted reliefs - such as exemptions for undue cost or effort - are introduced. The updates also enhance consistency, structure, and usability, while preserving the fundamental objectives of the CSRD framework.
IIGCC welcomes these efforts to simplify and clarify the ESRS framework, but stresses that robust, decision-useful disclosures must remain central. Our response endorses clearer materiality guidance, strong alignment with international standards, and connectivity between sustainability and financial reporting, to ensure investor needs are fully met.
Read our full consultation response and summary below.