Today the European Commission published the Draft Delegated ESRS Regulation, open for feedback until 3 June 2026.
The revised introduce minor targeted but meaningful changes to IRO and PATM (GDR) disclosures. The updates increase precision and streamline structure.
🌿 ESRS IRO & PATM: What Changed – and What It Means for Preparers
IRO Disclosures – Clearer, More Action‑Oriented
Most IRO requirements remain stable, but the Commission strengthens precision and action language:
- “Responded” changed to “Addressed” when describing how undertakings manage impacts, risks and opportunities. This shifts the emphasis from reaction to action‑oriented management, aligning with OECD/UNGP due‑diligence language.
- Exemption logic clarified: Instead of “cannot provide” the Commission uses “determines it need not provide”. This reframes omissions as reasoned determinations, not inability – raising the bar for justification.
PATM (GDR) – Structural Alignment & Due‑Diligence Upgrade
This is where the Commission introduces the most structural improvements.
- Policies (GDR‑P) – Expanded due‑diligence verbs: prevent, mitigate, bring to an end, minimise, remediate (instead of the narrower prevention/mitigation/remediation), aligned with UNGP/OECD.
- Actions (GDR‑A) – Scope and timeframe split into separate datapoints. Clearer structure, easier auditability.
- Targets (GDR‑T) – Restructuring: the Commission separates methodologies, legal requirements and scenarios into distinct datapoints. Improves transparency and aligns with climate/scenario‑based reporting.
- Metrics (GDR‑M) – Clarified that planned improvements to value chain data must be disclosed if such actions exist, now avoids implying that actions always exist. No change in substance, but expectations are clearer.
What This Means for Preparers
- Increased precision – ambition is not decreasing
- The Commission’s edits make requirements more precise, more auditable, and more aligned with global due‑diligence frameworks.
- Prepare for structured, modular reporting
- Explicit references to GDR‑P, GDR‑A, GDR‑T, GDR‑M signal a shift toward a modular, repeatable architecture.
- Good for tooling and comparability – but it requires early preparation and a move away from high‑level ESG storytelling.
- Exemptions now require explicit justification
- Expect auditors to challenge unsupported omissions.
- Supplementary information is now explicitly exceptional
- It must be clearly labelled, justified, and must not obscure mandatory disclosures.
- This is a direct warning against narrative-heavy reporting that dilutes required content.
The message is clear: start preparing now
The Commission’s refinements make one thing obvious: companies that wait will struggle. Expectations are firmer, structure is clearer, and interpretive flexibility is shrinking.
If you haven’t begun aligning your #strategy, #governance, and data model with the revised  #IRO and  #PATM requirements, now is the moment.
IRO, policy, target, action templates in Cleerit
We have updated the IRO-PAT templates in Cleerit. When using these templates correctly your disclosures will be compliant and can be automatically inserted in the corresponding ESRS datapoints. Contact us to get started >>>
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The Commission’s draft Sustainability reporting standard for voluntary use is also available here: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/17232-Sustainability-reporting-standard-for-voluntary-use_en
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Stay tuned for more CSRD, ESRS and VSME insights on our LinkedIn page >>
