Many companies have just adapted to the original ESRS from 2023 – and now the next version is here. The Omnibus ESRS draft from December 2025 brings real simplifications, but also new adjustment needs. What's changing, what's staying, and why the effort still remains considerable.
The brief overview
On December 3, 2025, EFRAG submitted its final draft of the simplified ESRS to the EU Commission.German Insurance Association The basis was the EU Commission's Omnibus Initiative, which aimed to ease sustainability reporting. The numbers sound impressive: 61 percent fewer mandatory data points compared to the original ESRS Set 1 from 2023German Insurance Association, 68 percent fewer total disclosures overall, standards more than 55 percent shorter.
Sounds like fundamental relief. In practice, the picture is more nuanced.
What was actually simplified
Aggregation instead of radical deletion. Many of the "eliminated" data points were not deleted, but consolidated into higher-level disclosures. Instead of five individual data points, there is now one summary mandatory disclosure – the content remains similar, but the form becomes more compact. Those who collected the original data points have therefore largely done work that remains relevant.
Voluntary data points are now truly voluntary. They have been removed from the main standards and transferred into a separate Non-Mandatory Implementation Guidance (NMIG). Going forward, companies only need to provide information that is "available without disproportionate cost or effort."KonBriefing
Materiality analysis more clearly structured. The approach is now explicitly top-down, with the business model as the starting point. The distinction between impacts, risks, and opportunities has been clarified to reduce duplicate documentation.
Value chain relieved. Going forward, disclosure of environmental and social metrics along the entire value chain is largely waived – the important Scope 3 greenhouse gas emissions remain an exception.KonBriefing
New General Disclosure Requirements. Cross-cutting disclosures are bundled instead of being repeated in each individual topical standard.
What hasn't substantially changed
And here lies the important point that many overlook in the headlines:
The core content remains. Climate protection, Scope 1/2/3, transition plans, human rights risks, governance disclosures – all of this remains mandatory. The reduction of data points doesn't mean topics are being dropped. It means the same topics are being reported more compactly.
The audit obligation remains. "Limited Assurance" by an auditor is still required. The associated costs will not decrease in the same way as the data points.
The methodology remains demanding. Double materiality analysis, IROs (Impacts, Risks, Opportunities), XBRL tagging – the conceptual complexity remains. The requirements are more clearly structured, but not simpler in the sense of "more superficial."
In short: the data points are leaner, but the substantive demands are not. Companies that hoped the Omnibus would turn the report into a finger exercise will be disappointed.
The adjustment effort during the transition
For companies that have already been working on the basis of the 2023 ESRS, additional adjustment effort paradoxically arises – not less:
Structural realignment. Internal processes, data models, and documentation structures must be adapted to the new General Disclosure Requirements and the consolidated ESRS 2 structure. Those who organized their processes according to the old structure are now reorganizing.
Mapping of data points. The remaining mandatory data points are not simply a subset of the old ones. Many have been reformulated, consolidated, or moved to other standards. A clean mapping between the old and new sets is necessary.
New materiality analysis. The top-down approach is not compatible with the previous, often bottom-up approach. In many cases, this means: the materiality analysis must be partially repeated.
Application date. According to EFRAG, mandatory datapoints have been reduced in the simplified ESRS by 61 %, and all voluntary datapoints have been removed, making the standards shorter, more accessible, and more coherent.Ergonomics Application is expected to apply for fiscal year 2027. Those currently reporting for 2026 are doing so based on the old standards – and will then switch.
And what about GRI reporters?
The good news: nothing fundamental has changed regarding interoperability between GRI and ESRS. Companies that report under ESRS automatically report "with reference to" the GRI Standards.ecovadis The GRI-ESRS Interoperability Index remains a useful tool, but will need to be adapted for the new standards.
What this specifically means for you
If you haven't started yet: Start directly on the basis of the new standards. The adjustment from old to new is eliminated.
If you're in the middle of the process: Check which preparatory work remains relevant (most data foundations do), where structure and narrative need to be adjusted, and plan a transition step.
If you've already reported under ESRS 2023: Expect a structural overhaul of your reporting setup. The data substance remains largely usable, the architecture not necessarily.
In all three cases: Sustainability reports under ESRS remain a serious project. The simplification noticeably reduces the effort, but it doesn't turn a regulatorily demanding report into a simple compulsory exercise.
Conclusion
The Omnibus ESRS are a step in the right direction – but not the relief that many headlines suggest. Data points have been aggregated, voluntary disclosures separated, structures organized. The substantive core remains. For reporting companies, this means: a real simplification effect in data collection, additional transition effort in the architecture – and still a substantial project that can hardly be efficiently managed without structured tools.
Want to know how your existing reporting setup can be transferred to the new Omnibus ESRS and where AI support can reduce the transition effort? Glacier supports you with mapping, gap analysis, and data architecture. Book a demo now.
