Webinar: Moving forward with EFRAG’s simplified ESRS

How can companies navigate the latest ESRS updates and ensure they are ready for the coming reporting cycles? This session provided a clear walkthrough of the revisions and practical considerations for 2026 and beyond.

On December 9, Nordic Sustainability hosted a webinar on the revised ESRS and the latest developments in the Omnibus negotiations. The panel brought together Anniina Kristinsson, Managing Partner, and Julia Goertz, Senior Consultant, from Nordic Sustainability, joined by Merete Lerche Thinggaard, Senior Lead ESG Specialist at Ørsted and Camilla Adamsen Nielsen, Associate in DCM and Sustainability at Nykredit.

Updates on the Omnibus status

Anniina Kristinsson opened with timely news. The night before, the trilogue negotiations had reached their conclusion on the CSRD.

Next steps include a vote in the Legal Affairs Committee, followed by a Parliament vote during the December plenary session. The Council will then need to endorse and adopt the agreement.

In parallel, EFRAG has finalised its simplified ESRS drafts. These revisions aim to reduce unnecessary burden, improve readability, and align more closely with the purpose of sustainability reporting: providing useful, decision-relevant information.

With an estimated 61 percent reduction in data points, the new standards are shorter and more principles-based, meaning they set objectives for what companies need to disclose rather than prescribing a fixed format. This gives companies more flexibility in how they structure their disclosures while still ensuring that the information forms a coherent overall picture.

The EU Commission will still need to adopt the revised ESRS in a delegated Act at the latest 6 months after entering into force of CSRD amendments, but the broad outlines are now set.

Technical walkthrough of key ESRS changes

EFRAG and the European Commission have introduced a package that change both the architecture of the standards and what is expected from companies in practice. Julia Goertz outlined the core measures.

What the simplification looks like on paper

Several reliefs have been built in. Companies can phase in complex disclosures, use estimates where appropriate, and exclude activities that are not significant drivers of impacts, risks, or opportunities. Interoperability with ISSB has also improved, reflected in updated GHG boundary rules and clearer treatment of anticipated financial effects.

Examples across E, S and G

The revised standards introduce targeted changes to reduce complexity and focus attention on the areas that matter most. Taken together, these adjustments reduce reporting burden while creating a more focused set of disclosures for material topics.

On the environmental side, several metrics have been consolidated, and core concepts have been clarified. E1 aligns GHG boundaries more closely with the GHG Protocol. E3 makes water withdrawals and discharges mandatory. E4 narrows and reorganises biodiversity reporting, with clearer expectations for sites affecting sensitive areas. E5 introduces new disclosures on critical raw materials and waste with unknown destinations.

Social disclosures have been streamlined, particularly in S1, where the number of workforce metrics has been reduced and expectations around engagement and remediation are clearer.

Governance reporting has been restructured to match the other standards, with granular datapoints removed to avoid duplication and improve coherence.

Taken together, these adjustments reduce reporting burden while creating a more focused set of disclosures for material topics.

For companies going into 2026

The simplifications reduce the administrative load, but they also shift responsibility to companies to explain their scoping decisions, assumptions, and boundaries more clearly. Good reporting will depend on transparent accounting policies rather than rigid templates. Alongside the technical changes, the discussion turned to what companies should prioritise in the coming year.

Wave 1: simplify and professionalise

• Use the 2025–2026 quick-fix reliefs but use them carefully. They reduce the burden, but investors and lenders will still expect solid analysis beneath the surface
• Plan your transition to the revised ESRS. Decide whether your future reporting will follow the full or simplified standards and adjust your reporting architecture accordingly
• Streamline rather than comply mechanically. Use your 2025 and 2026 reports to remove generic content and focus on strategy, risks, capital allocation, and performance
• Strengthen governance and assurance readiness. Robust internal controls will be critical as assurance requirements continue to increase

Wave 2: the postponement doesn’t change the direction of travel

• Use the postponement as a build period. Approach 2026–2027 as the time to establish systems, processes, documentation, and controls, not as a period to defer work
• Anticipate value chain expectations. Requests for sustainability data will continue regardless of scope, so clarify now what you aim to collect, disclose, and potentially decline

Flexibility reliefs will provide reader friendliness but should not compromise comparability and discipline

Merete Lerche Thinggaard from Ørsted shared that the revised ESRS allows companies to tailor disclosures more closely to what is decision-useful for investors and analysts, rather than following a rigid structure.

The ability to reorganise content, include summaries, and move static information to appendices makes it easier to produce reader friendly reports that reflect the company’s actual performance story rather than a prescribed format.

At the same time, Merete noted that flexibility should not compromise comparability or discipline. Limited assurance remains an important anchor.

Companies will still need clear internal documentation to justify exclusions, including for qualitative disclosures, and auditors will expect a transparent rationale for each decision. This should prevent “cherry-picking” while still enabling companies to avoid unnecessary detail.

The demand for credible ESG data from capital providers will not diminish

Camilla Adamsen Nielsen from Nykredit highlighted that the simplification of ESRS does not lessen the requests and requirements companies face from their financial stakeholders.

Danish Banks now have a legal obligation to monitor the bank’s ESG risks on portfolio level by integrating ESG risks into credit assessments, and this applies far below the CSRD threshold: Nykredit assesses ESG risks for corporate clients with loan exposure above 20 million DKK.

Her team works on two fronts. On one side, they advise clients on sustainable finance instruments and management of financial material ESG risks. On the other, they evaluate the ESG risks that could affect the bank’s own balance sheet. Because a client’s ESG risk becomes a lender’s risk, banks will continue to request data on emissions, transition plans, and broader ESG performance regardless of whether a company is in scope of the simplified ESRS or CSRD.

Camilla noted that many companies are surprised to learn the EBA Guidelines is an EU-wide ”comply or explain” for national competent authorities and implemented in different forms on country level, not just sustainability policy. For 2026, banks will focus on building comprehensive ESG risk profiles of their clients, mapping impacts and emissions across their loan books. This means that even companies exempt from CSRD should expect ongoing and structured data requests from lenders.

Want to get started or get further?

Nordic Sustainability is monitoring the developments of the Omnibus negotiations closely. If you’d like to understand how potential outcomes could affect your organisation, we’re happy to talk.

Reach out to our Managing Partner Anniina Kristinsson at akr@nordicsustainability.com to get started.

Further reading:

Bill L 193 B Forslag til lov om ændring af lov om finansiel virksomhed, lov om forvaltere af alternative investeringsfonde m.v., lov om investeringsforeninger m.v., hvidvaskloven og forskellige andre love: https://www.ft.dk/samling/20241/lovforslag/l193b/index.htm

European Banking Authority’s Guidelines on the management of ESG risks: https://www.eba.europa.eu/activities/single-rulebook/regulatory-activities/sustainable-finance/guidelines-management-esg-risks