Delivering on the Omnibus I simplification mandate: IOGP Europe position on the draft Sector-Agnostic European Sustainability Reporting Standards (ESRS)

EXECUTIVE SUMMARY

The Omnibus I simplification package was intended to materially reduce sustainability reporting burden while preserving decision-useful information. Despite a simplified structure, streamlining of general disclosure requirements and the introduction of reliefs, the November 2025 draft Sector Agnostic ESRS, as reflected in EFRAG’s technical advice of 3 December 2025, does not deliver meaningful simplification. Instead, the cumulative effect of the following changes has increased reporting burden and legal and implementation risks, rather than simplification:

• New reporting concepts and datapoints have been introduced
• Requirements across ESRS 1, ESRS 2 and several topical standards have become more prescriptive
• Misalignment with global frameworks, including ISSB has widened, increasing duplication for globally operating undertakings
• Reporting scope, documentation demands and assurance exposure remain largely unchanged

The draft ESRS continue to rely on unstable materiality boundaries, expansive value chain expectations and highly granular environmental disclosures, alongside reconciliation requirements with financial reporting and other frameworks. New disclosure obligations have also been introduced in areas where methodologies and assurance practices are not yet sufficiently mature.

Headline reductions in datapoints cited in the cost-benefit analysis are largely driven by consolidation and voluntary “may” provisions and are therefore unlikely to translate into a meaningful reduction in reporting scope, effort or cost.

Proposed way forward

Meaningful simplification under Omnibus I requires proportionality and relief mechanisms to operate as binding design constraints, not discretionary features. While references to feasibility and the use of reasonable and supportable information represent one of the few areas of tangible simplification, these reliefs remain vulnerable to erosion through assurance and supervisory interpretation. Without explicit protection, they risk incentivising defensive documentation and conservative over-reporting.

Reliefs alone cannot compensate for disclosure requirements that are structurally over-prescriptive or insufficiently mature. Simplification therefore requires protecting materiality and scoping decisions in practice and avoiding speculative modelling, forward-looking disclosures, un-auditable methodologies, and open-ended scoping. IOGP Europe therefore calls for further enhancements in the final Delegated Act adopting the simplified ESRS, with a clear focus on information that is material, decision-useful and operable.

This position paper sets out a focused set of priority adjustments that should be addressed before adoption of the revised ESRS, to ensure legal certainty, auditability and practicable implementation in line with the policy objectives of the Corporate Sustainability Reporting Directive (CSRD).

Download the document to read the full list of priorities