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Update
14.01.2025
July 2025:

ICMA publishes updates on green, social, and sustainability bond principles

On 26 June, the International Capital Market Association (ICMA) published guidance on its Green, Social, Sustainability and Sustainability-Linked Bond Principles. The key publication is the practitioner’s guide on Sustainable Bonds for Nature. Links to other guidance documents and updates can be found here.

GRI publishes updated reporting standards on climate change and energy

On 26 June, the Global Reporting Initiative (GRI) published updated voluntary reporting standards on climate change and energy (available at the bottom of this page as GRI 102 and GRI 103, including FAQs). The update incorporates recent developments and intergovernmental instruments. The climate change reporting standards aim to incorporate reporting on just transition principles, climate change mitigation and adaptation strategies, emissions reduction targets and progress, GHG removals within the value chain, and the use of carbon credits. The energy reporting standards include a management disclosure on energy policies and commitments, as well as reporting on topics such as energy consumption and generation by the own organisation and the upstream and downstream value chain, energy intensity, and reduction of energy consumption. On 23 June, GRI also published the Sustainability Taxonomy, which is a machine-readable version of the GRI standards based on the XBRL.

IFRS Foundation publishes guidance on climate transition plan disclosures

On 23 June, the International Financial Reporting Standards (IFRS) Foundation released new guidance to support companies in disclosing transition plans under IFRS S2 on Climate-related Disclosures. The guide aims to bring greater consistency to how companies report on their climate transition strategies. It supports the ISSB’s global baseline by helping entities explain how they set climate targets, take action, and allocate resources to address climate-related risks and opportunities, and clarifies what must be disclosed under IFRS S2 for companies with a transition strategy.

EFRAG targets 50% reduction in ESRS datapoints to ease CSRD reporting burden

On 20 June, EFRAG published a progress report on its work to simplify the European Sustainability Reporting Standards (ESRS) as part of Omnibus. EFRAG expects to reduce the number of ESRS datapoints by at least 50%, particularly by eliminating excessively detailed narrative disclosures. At the same time, it intends to maintain the CSRD’s core objectives. ESRS identifies six simplification levers: (i) streamlining the double materiality assessment (DMA); (ii) improving readability and conciseness of sustainability disclosures; (iii) clarifying the link between minimum disclosure requirements (MDR) and topical standards to avoid duplication; (iv) enhancing understandability and accessibility of the ESRS; (v) targeted burden reliefs; and (vi) strengthening interoperability with international frameworks, such as the ISSB standards. EFRAG aims to approve the ESRS draft by mid-July 2025 and launch a public consultation shortly thereafter. It aims to deliver its technical advice to the EC by 31 October 2025.

ESMA issues statement on first-time application of ESRS and supervisory expectation

On 20 June, ESMA published a public statement on the supervision of sustainability reporting in the context of the first application of the ESRS. ESMA acknowledges the uncertainty caused by the simultaneous introduction of the ESRS, the incomplete transposition of the CSRD into national law, and ongoing Omnibus proposals. Together with national competent authorities (NCAs), ESMA reaffirms its commitment to transparent sustainability reporting, the prevention of greenwashing, and a proportionate and realistic supervisory approach. The application of the ESMA Guidelines on Enforcement of Sustainability Information (GLESI), in force since January 2025, will be approached flexibly during the initial phase to accommodate the learning curve for both companies and regulators.

EU accounting boards jointly call for simplification of sustainability reporting standards

On 20 June, the national accounting standard setters of France, Germany, Italy, and Spain (ANC, DRSC, OIC, and ICAC) jointly submitted a staff working paper to EFRAG urging a major simplification of the ESRS. The proposal advocates a more pragmatic and business-oriented approach to ESG reporting, easing the growing compliance burden faced by companies under the CSRD. The paper calls for a substantial reduction in datapoints, particularly those outside a company’s control or business scope, and includes targeted recommendations such as: streamlining double materiality assessments, limiting value chain disclosures, especially quantitative data on upstream and downstream activities, clarifying expectations for financial effects disclosures in line with ISSB practices, making operational control reporting optional to increase flexibility, improving alignment with ISSB standards for global interoperability, and enhancing coordination with the SFDR to create a more integrated EU sustainability reporting framework.

EP committee publishes study on EU sustainability reporting rules and Omnibus

On 13 June, the European Parliament’s JURI Committee published a study on EU sustainability reporting obligations under CSRD, CSDDD, and the Taxonomy Regulation. While recognising the burdens associated with these reporting obligations, the study does not find explicit overlaps. The report offers recommendations for smarter integration of requirements and streamlining of obligations. The study also identifies several defects in the political process regarding Omnibus, including the neglection of available evidence and lack of stakeholder consultation. The study urges the EC to reconsider its legislative proposals and to clarify how anticipated burden reductions compare to potential losses in transparency, governance quality, risk management, and stakeholder trust, especially when removing sector-specific standards or altering requirements without clear justification.

TNFD publishes final guidance for ocean sectors and launches consultation on metrics

On 6 June, the TNFD published final sector guidance for fishing, marine transport, and cruise lines, helping companies assess and disclose their impacts on ocean ecosystems. Key topics include overfishing, IUU fishing, and marine protected areas. TNFD also launched a consultation on ocean-related metrics, open until 1 October 2025, aimed at improving data and supporting the LEAP risk assessment process. The guidance and consultation mark a key step in integrating ocean health into financial and corporate decisions.

Previous updates

  • June

    EFRAG publishes digital template for VSME disclosures

    On 27 May, the European Financial Reporting Advisory Group (EFRAG) published a VSME Digital Template and VSME XBRL Taxonomy, including other resources, to support companies with fewer than 250 employees in applying the VSME reporting standard. They were developed in response to feedback from preparers and users during the public consultation on the VSME Exposure Draft, which took place from 22 January to 21 May 2024. The VSME Digital Template (Excel) aims to enable user-friendly data entry, including interactive checkboxes and validations to determine which disclosures are required, auto-calculation of totals, validations and consistency checks, and drop-down menus and checkboxes for semi-narrative disclosures. The VSME XBRL Taxonomy enables the digitalisation of VSME disclosures by providing an independent data model of VSME disclosures, allowing reporting in various technical formats, facilitating data exchange and database imports using a structured, license-free, and open format.

    EC to propose relief from ESRS phase-in requirements for wave 1 companies

    On 13 May, EC representative Tom Dodd announced in a JURI public hearing that the EC will propose a delegated act to relieve companies currently reporting under CSRD (so-called wave 1 companies) from the phase-in requirements under the ESRS, such as E1-9 (‘Anticipated financial effects from material physical and transition risks and potential climate-related opportunities’). The other CSRD and ESRS reporting requirements would remain applicable to these companies, pending the substantive Omnibus proposal.

    TNFD launches global survey on nature-related reporting practices

    On 7 May, the Taskforce on Nature-related Financial Disclosures (TNFD) launched a survey for corporates, financial institutions, and market service providers. The aim is to better understand how organisations are currently assessing and reporting nature-related risks and dependencies. Insights will help shape future guidance and support effective implementation of the TNFD framework. The survey also seeks to identify key challenges and emerging best practices in biodiversity and ecosystem-related disclosures. The survey is open until 1 August 2025.

    ESMA publishes guidelines on supervision of CSRD reporting by listed companies

    On 29 April, the ESMA published final Guidelines on Enforcement of Sustainability Information (GLESI). The Guidelines must be applied by national supervisory authorities in their supervision of sustainability reporting under CSRD by listed companies. It provides 22 principles-based guidelines. National authorities must apply the Guidelines to sustainability information published by listed companies from 1 January 2025. By 29 June 2025, authorities must notify ESMA whether they comply with the Guidelines.

    B Corp updates certification standards

    On 28 April, B Lab published revised standards for the voluntary B Corp certification framework (see also the summary). The revised standards are more ambitious than the current standards and require phased improvement to maintain B Corp certification. The number of impact areas will be expanded from five to seven. Companies generating more than 1% revenue from certain sectors, including gambling, tobacco, fossil fuel production, or weapons, will not be eligible for B Corp certification. Companies selling or supplying products in the EU that carry the B Corp label must recertify before 27 September 2026, as the current B Corp regime does not comply with new EU anti-greenwashing rules that will apply as of that date. For new B Corp certifications, the revised standards will apply from 2026. For recertifying companies, phase-in provisions apply.

  • May

    ISSB launches consultation on IFRS S2 climate disclosure standard

    On 28 April 2025, the International Sustainability Standards Board (ISSB) launched a public consultation on its Exposure Draft proposing amendments to the IFRS S2 climate-related disclosures. The proposed amendments relate to the application of the GHG emissions disclosure requirements under IFRS S2, including:

    • relief from Scope 3 Category 15 GHG emissions disclosure associated with derivatives and some financial activities;
    • relief from the Global Industry Classification Standard (GICS), in some circumstances, in disclosing disaggregated financed emissions;
    • the use of alternatives for the Greenhouse Gas Protocol measuring instrument; and
    • the use of Global Warming Potential (GWP) values other than from the Intergovernmental Panel on Climate Change (IPCC).

    Companies currently applying IFRS S1 and IFRS S2 as issued in June 2023 can continue doing so. The consultation is open until 27 June 2025.

    EFRAG publishes workplan for ESRS revision

    On 25 April, EFRAG published its workplan for revising the European Sustainability Reporting Standards (ESRS) in the context of the Omnibus proposal. EFRAG aims to submit its draft revised ESRS to the EC by 31 October 2025. The objective is to deliver a set of ESRS that better support relevant, decision-useful sustainability disclosures for general purposes, while significantly reducing reporting burdens and the number of mandatory datapoints. Between April and October 2025, EFRAG will follow a six-step process, which includes evidence gathering, analysis of stakeholder input, drafting and publishing of exposure drafts, and finalisation of its technical advice to the EC.

    EFRAG launches public consultation on simplification of ESRS under Omnibus

    On 8 April, the European Financial Reporting Advisory Group (EFRAG) launched a public consultation on the first set of simplifications of the European Sustainability Reporting Standards (ESRS). Stakeholders are invited to provide input on, inter alia, ESRS mandatory datapoints that are least important or problematic for general-purpose sustainability, per Disclosure Requirement; suggestions on how to modify unclear ESRS provisions; suggestions to improve consistency with other EU legislation; suggestions on how to improve the ESRS provisions on materiality; suggestions on how to simplify the structure and presentation of the standards; suggestions on how to further enhance interoperability with global sustainability reporting standards; and any other modifications that could simplify the ESRS without compromising their role in supporting the Green Deal. The consultation is open until 6 May.

  • April

    PSF responds to public consultation on Taxonomy Delegated Acts

    On 26 March, the Platform for Sustainable Finance published its response to the EC public consultation on the proposed amendments to the Taxonomy Delegated Acts under the Omnibus proposals. PSF strongly recommends preserving the CSRD’s original scope and aligning the scope of Taxonomy reporting with that original scope. For non-SME companies below the 1,000-employee threshold, reporting should focus on the most essential standards, including Taxonomy alignment. PSF welcomes proposals to simplify and reduce corporate reporting obligations, simplify the GAR and DNSH, postpone the ‘trading book’ and ‘fees and commissions’ KPIs for banks, and improve SMEs’ access to sustainable finance. However, PSF has ‘serious concerns’ about the narrowing of the scope of CSRD and the Taxonomy due to the potential loss of data.

    EFRAG publishes educational videos on ESRS digital tagging

    On 20 March, EFRAG published two educational videos demonstrating the digital tagging of an ESRS report using the ESRS Set 1 XBRL Taxonomy. The videos explain that any compliant XBRL tool can be used. Final tagging rules (ESEF RTS) will be issued by ESMA and the European Commission.

    EFRAG and CDP publish compliance table on ESRS E1 and CDP

    On 18 March, EFRAG and the Climate Disclosure Project (CDP) published correspondence mapping between the CDP question bank and ESRS E1. It provides an overview of reporting requirements of CDP and ESRS E1, highlighting areas of overlap. The mapping aims to promote interoperability and reduce the need for multiple reports.

    ECB publishes paper on EU corporate disclosure rules and greenwashing

    On 14 March, the ECB released an occasional paper examining how the EU’s regulatory framework addresses the growing concern of greenwashing, particularly in corporate disclosures. The paper explores how the EU’s sustainability disclosure framework – including the EU Taxonomy, CSRD, ESRS, and CSDDD – aims to combat greenwashing and align corporate actions with the EU Climate Law’s net-zero goals for 2050. Greenwashing, driven by vague or misleading sustainability claims, remains a significant risk due to the lack of standardised reporting. It undermines investor confidence and the transition to a low-carbon economy. The paper highlights that this regulatory package promotes greater transparency, comparability, and accountability. It also provides enforcement and sanctioning powers, giving real weight to the rules. The paper notes that banks face parallel ESG and disclosure requirements under the EU’s banking package. Looking ahead, the paper acknowledges that the 2025 Commission work programme and the Omnibus package propose simplifying sustainability rules. However, any future reforms should stay closely linked to the current disclosure framework to effectively mitigate greenwashing risks.

    EC publishes notice on interpretation and implementation of EU Taxonomy Delegated Acts

    On 5 March, the EC published a notice in the Official Journal of the EU providing guidance on the interpretation and application of specific provisions within the Taxonomy Regulation delegated acts. The notice offers technical clarifications in response to frequently asked questions. Structured across nine sections, the document addresses general queries, as well as questions related to both climate objectives (climate change mitigation and adaptation) and environmental objectives (such as water and marine resources, circular economy, and more). It also covers the application of the “do no significant harm” criteria, the scope of CapEx and OpEx reporting, and timeframe for reporting on Taxonomy eligibility and alignment.

  • March

    EU-wide tracker of CSRD reports published

    The Sustainability Reporting Navigator published an open source EU-wide tracker of published CSRD sustainability statements. It links to published annual reports and indicates the relevant pages for finding the CSRD sustainability statements.

  • February

    ISSB publishes guide on climate only IFRS disclosures

    On 30 January, the International Sustainability Standards Board (ISSB) released a guide ‘Applying IFRS S1 when reporting only climate-related disclosures in accordance with IFRS S2’. This guide is designed to help companies report only climate-related information, when applicable, using the ISSB Standards. It specifies which IFRS S1 should be reported on when companies apply the ISSB’s climate-first transition relief. The guide addresses investors’ feedback, highlighting the urgent need for climate-related information and the challenges in data availability and companies’ readiness for other sustainability-related risks and opportunities.

    Dutch Ministry of Economic Affairs publishes ESRS navigator 2025

    On 25 January, the Dutch Ministry of Economic Affairs and Climate (EZK) published the ESRS Navigator 2025. The navigator aims to help companies reporting under the CSRD’s European Sustainability Reporting Standards (ESRS). It provides insights into the context and structure of the ESRS, practical guidance, and a case study. The Ministry also released an Excel overview of datapoints to be collected for ESRS reporting.

    TNFD publishes sectoral guidance on nature disclosures

    On 23 January, the Taskforce on Nature-related Financial Disclosures (TNFD) published sectoral guidance for four industries:

    1. apparel, accessories and footwear
    2. beverages
    3. construction materials
    4. engineering, construction and real estate

    This guidance aims to help organisations to identify, assess and report on their nature-related dependencies, impacts, risks and opportunities. It the TNFD’s principal Guidance on the assessment of nature-related risks. TNFD also initiated consultations on new sectoral guidance for:

    1. fishing
    2. marine transportation and cruise lines
    3. water utilities and services

    These consultations are open until 3 April 2025.

    EC and EFRAG publish paper on ESRS and EMAS synergies

    On 16 January, the EC and EFRAG published a joint paper on the synergies between the ESRS and the voluntary Eco-Management and Audit Scheme (EMAS) framework. This paper aims to streamline sustainability reporting for companies already reporting under EMAS, by providing a detailed overview of overlapping disclosures. It allows for incorporation by reference of companies’ EMAS disclosures in their ESRS disclosures under the CSRD.

    Dutch CSRD implementation act submitted to House of Representatives

    On 13 January, Dutch Parliament submitted the proposal for the Dutch CSRD Implementation Act to the House of Representatives. This proposal includes the explanatory memorandum, the advice of the Council of State, and the Minister’s further report. The act implements the CSRD’s rules on accountants and accounting firms, and the general availability of sustainability reporting by listed companies. The specific sustainability reporting obligations for companies (ESRS) will be detailed in a separate Order in Council (AMvB) based on Book 2 of the Dutch Civil Code (Implementatiebesluit richtlijn duurzaamheidsrapportering). Key aspects of the proposed implementation act include:

    The exact date of entry into force remains unknown, while the directive was supposed to be transposed into national legislation by 6 July 2024.

  • January

    EFRAG publishes new Q&As on ESRS
    On 24 December, the European Financial Reporting Advisory Group (EFRAG) added three new explanations of the European Sustainability Reporting Standards (ESRS) to its ESRS Q&A platform, bringing the total number of explanations to 162. The new Q&As address: (i) the possibility for credit institutions to omit reporting in absolute values on their intensity-based GHG reduction targets during the first three years of reporting; (ii) the possibility to limit disclosures on biodiversity to the undertaking’s upstream or downstream; and (iii) the scope of certain disclosure requirements in ESRS E4. These explanations will be included in the next update to the Compilation of Explanations, expected in spring 2025.

    Dutch accountants’ institute publishes statement on CSRD assurance
    On 20 December, the Royal Netherlands Institute of Chartered Accountants (NBA) issued a statement on the assurance of sustainability statements by Dutch companies under the Corporate Sustainability Reporting Directive (CSRD). Since the CSRD has not yet been implemented into Dutch law, accountants lack a legal basis for this assurance. The NBA advises accountants to act in line with the legislative proposals as much as possible. The accountant’s assurance must address the fundamental qualitative characteristics of the ESRS, which include relevance and faithful representation, as well as their reinforcing qualitative characteristics: comparability, verifiability and understandability.

    EFRAG publishes voluntary reporting standard for micro-, small-, and medium-sized undertakings
    On 17 December, EFRAG delivered its technical advice on the voluntary reporting standard for non-listed micro-, small-, and medium-sized undertakings (VSME). Based on market acceptance, the VSME provides a standardised set of information to replace the current multiple and uncoordinated questionnaires and ESG data requests. It includes a basic module and a comprehensive module, which are expected to meet a substantial part of the requests that SMEs currently receive from business partners, such as banks, investors and large corporates. The VSME includes disclosures for undertakings across sectors. However, a few additional data requests may be required to reflect the specificities of some sectors. The VSME is accompanied by a series of educational videos.

    EU Platform on Sustainable Finance publishes briefing on SFDR revision
    On 17 December, the EU Platform on Sustainable Finance (PSF) published a briefing in response to the EU public consultation on the revision of the SFDR. The PSF recommends establishing four product categories: (i) sustainable; (ii) transition; (iii) ESG collection; and (iv) unclassified products. ‘Sustainable’ products must meet a minimum percentage of EU Taxonomy-alignment or alignment with the SFDR definition of sustainable investments and PAI thresholds. ‘Transition’ products must foster the transition to a net zero and overall sustainable economy by 2050, and milestones in line with these EU goals, based on a legal definition of impact investing. ‘ESG collection’ products select or exclude sectors or companies based on their ESG performance. The ESAs already proposed the first and second categories in June 2024; the third category is additional to the ESAs’ proposal.

    ESMA publishes consultation paper on ESEF application for sustainability reporting
    On 13 December 2024, the European Securities and Markets Authority (ESMA) released a consultation paper, including Annex VII (core ESRS taxonomy), Annex VIII (core Article 8 taxonomy), and a Taxonomy set prototype. The paper explores how the European Single Electronic Format (ESEF) can be applied to sustainability reporting. It aims to reduce the burden of financial reporting. The digitised sustainability and financial data will be integrated into the future European Single Access Point (ESAP) for easier access and use by investors. Key proposals are: (i) defining tagging rules for sustainability reporting, with phased implementation over three steps, each lasting two years, and full implementation for Article 8 information; (ii) redefining tagging for notes in consolidated IFRS financial statements; and (iii) amending technical standards related to the European electronic access point. The consultation is open until 31 March 2025, with a final report expected in Q3 2025.

    AFM publishes ‘market watch’ on CSRD and green bonds
    On 10 December, the Dutch Authority for the Financial Markets (AFM) published the twelfth edition of its AFM Market Watch, focusing on its supervision on the CSRD and the EU Green Bond Regulation. Key points regarding CSRD-related data include reliability, clarity, and consistency, which must be clearly presented and substantiated. The AFM acknowledges the challenges companies face in implementing new regulations and encourages progress over perfection in the initial phase. However, issuers in regulated prospectuses must provide a sustainability report covering key material topics and a prospectus containing material sustainability information for investors. AFM will act on clear violations.

    EFRAG publishes new compilation of technical ESRS explanations
    On 6 December, the European Financial Reporting Advisory Group (EFRAG) published 64 new explanations on the ESRS, including a mapping of sustainability matters to topical disclosures. These explanations cover expected decimals, time horizons, intensity-emission and absolute-emission targets, anticipated financial effects, and the structure of sustainability statements. The mapping supports undertakings in determining disclosure requirements related to specific material sustainability matters in the corresponding topical ESRS. The mapping takes these differences of architecture of topical standards into account and provides an overview of direct links between matters and Disclosure Requirements or datapoints.

  • ESG disclosure updates in 2024

    See our overview of ESG disclosure updates in 2024

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