Amended ESRS 2025
EFRAG published the Amended ESRS in December 2025 — reducing mandatory datapoints by approximately 61% following the Omnibus package. Understanding exactly what changed, what remained, and what the reduction means for your reporting is essential for Wave 2 compliance planning.
EFRAG published the Amended ESRS in December 2025 — reducing mandatory datapoints by approximately 61% following the Omnibus package. The '61% reduction in mandatory datapoints' headline requires context — it does not mean CSRD is 61% simpler.
What the 61% reduction means in practice
The '61% reduction in mandatory datapoints' headline requires context — it does not mean CSRD is 61% simpler. The reduction focuses on specific sub-datapoints within each standard, not on the removal of whole disclosure requirements.
What was reduced: Granular sub-breakdowns within larger disclosures — for example, requiring GHG emissions by type and by business activity was simplified to total by scope; certain qualitative narrative disclosures were moved from mandatory to recommended; some detailed governance sub-disclosures were removed; and specific quantitative metrics within ESRS S1 (certain non-employee worker breakdowns) and ESRS E3/E4 were shifted to voluntary.
What was not reduced: The core mandatory disclosures remain — Scope 1, 2, and 3 GHG emissions; EU Taxonomy KPIs; double materiality assessment; ESRS 2 governance disclosures (GOV-1 through GOV-5); health and safety metrics; gender pay gap; transition plan; and climate scenario analysis. The reduction did not eliminate any of the most significant first-year compliance challenges.
The practical effect: A Wave 2 company reporting under Amended ESRS will produce a somewhat shorter and less granular report than a Wave 1 company reporting under original ESRS — but the data collection and infrastructure requirements are not dramatically different. The Amended ESRS reduces reporting burden at the margins, not at the core.
Key changes by ESRS standard
ESRS 2 (General Disclosures): Reduced mandatory governance sub-disclosures — some GOV and SBM sub-elements moved to voluntary. The core GOV-1 through GOV-5 structure remains. Board and management disclosures, stakeholder engagement, and material IRO identification remain mandatory.
ESRS E1 (Climate): The transition plan, GHG targets, Scope 1/2/3 emissions, energy metrics, and scenario analysis remain mandatory. E1-9 financial effects quantification is simplified — less prescriptive quantification methodology for transition and physical risk financial effects.
ESRS E2 (Pollution): Core pollutant emission metrics remain. Some sub-breakdowns by individual pollutant type within categories were simplified.
ESRS E3 (Water) and E4 (Biodiversity): Some site-level detail requirements were reduced. Core withdrawal/consumption metrics (E3) and TNFD-aligned assessment (E4) remain. Financial effects quantification (E3-5, E4-6) has phase-in relief extended for Wave 2.
ESRS E5 (Circular Economy): Resource inflow and outflow core metrics remain. Some granular sub-breakdowns simplified.
ESRS S1 (Own Workforce): Core metrics — headcount, H&S, pay gap, CEO ratio, training — remain mandatory. Some granular non-employee worker breakdowns simplified. Collective bargaining coverage remains mandatory.
ESRS S2, S3, S4 (Value chain, communities, consumers): Core policy and action disclosures remain. Some target sub-requirements and engagement detail reduced.
ESRS G1 (Business Conduct): Core anti-corruption, payment practices, and lobbying disclosures remain. Minimal changes.
Using the Amended ESRS for Wave 2 planning
Wave 2 companies should base their entire compliance programme on the Amended ESRS — not the original 2023 version. Working from the wrong version wastes effort on disclosures that are no longer mandatory.
Amended ESRS access: The Amended ESRS standards are published on the EFRAG website (efrag.org) and in the EU Official Journal. Download the current text and use it as the definitive reference for your gap analysis and data collection planning.
Gap analysis recalibration: If your organisation conducted a preliminary gap analysis against the original ESRS in 2024 or early 2025, recalibrate against Amended ESRS. Some data collection activities previously planned may no longer be mandatory — freeing resource for higher-priority gaps.
Updated XBRL taxonomy: EFRAG updated the ESRS XBRL Taxonomy to reflect Amended ESRS datapoints. Ensure your XBRL implementation uses the Amended ESRS taxonomy version — not the original 2023 taxonomy. This affects the number and identity of required tags in your sustainability report.
Stakeholder communication: Communicate the Amended ESRS changes to internal stakeholders — finance teams, H&S teams, and IT who are building data collection infrastructure. The reduction in some datapoints may affect data architecture decisions. Avoid building infrastructure for disclosures that are no longer mandatory.
Frequently asked questions
Does the Amended ESRS apply retroactively to Wave 1 companies already reporting?
Wave 1 companies continue reporting under the original ESRS framework with specific transitional provisions. Some Amended ESRS reliefs apply to Wave 1 ongoing reports — check EFRAG's Wave 1 relief guidance. Wave 1 companies do not automatically switch to Amended ESRS — the Amended ESRS is the mandatory framework for Wave 2 companies from FY2027.
Where can I find the exact list of datapoints removed in the Amended ESRS?
EFRAG published a detailed comparison table alongside the Amended ESRS showing original datapoints, their Amended ESRS status (mandatory, voluntary, removed), and the rationale. This table is the authoritative reference — download it from efrag.org. For Wave 2 gap analysis, use the Amended ESRS mandatory datapoint list directly rather than inferring from the comparison table.
Does the 61% reduction mean we need 61% less data collection?
No — the 61% reduction is in the number of reportable datapoints, not in data collection effort. The mandatory disclosures that drive the most significant data collection effort — Scope 3 GHG emissions, supplier engagement, materiality assessment, health and safety metrics — remain unchanged. The reduced datapoints are primarily sub-breakdowns and supplementary disclosures that add reporting complexity but relatively limited data collection burden.