Amended ESRS Exposure Draft July 2025 Public Consultation Survey

IOGP Europe has submitted its response to EFRAG’s consultation on the Amended European Sustainability Reporting Standards (ESRS), a consultation that was launched at the explicit request of the European Commission earlier this year, and in the context of the 1st Simplification Omnibus published on the 26th of February.

We call on EFRAG to streamline requirements where overlaps or redundancies exist, preserve what is decision-useful, and strengthen interoperability across EU and global frameworks, so that companies operating internationally can comply efficiently without perceiving European reporting as a disproportionate burden or a risk to competitiveness.

What we support
• A clearer, principles-based approach to double materiality that avoids checklist reporting and keeps the materiality filter front and center
• Better readability and connectivity of sustainability statements, including concise front-end summaries and sensible aggregation
• Flexibility to report environmental metrics under an operational-control boundary for E2–E5, consistent with industry practice

Where further work is needed
• Keep the DMA principles-led; avoid a gross-only treatment of impacts that inflates disclosures and obscures what matters
• For anticipated financial effects, focus on qualitative disclosures until methods mature; avoid speculative quantification that risks inconsistency, legal exposure, and assurance disputes
• In social standards, retain the focus on severe human-rights incidents for clarity and proportionality
• Resist re-introducing complexity via new or duplicate datapoints, and streamline ARs that read as guidance rather than requirements

Our aim is a reporting framework that is clear, proportionate, interoperable and decision-useful for investors and stakeholders, while remaining workable for preparers.

Download the document to see the detailed response

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