🔎 What the financial and supervisory authorities expect from the revised ESRS

When the European Commission adopts the delegated acts on the ESRS, it must consider EFRAG’s draft (December 2025) and request the opinions of a wide range of EU bodies — including ESMA, EBA, EIOPA, the ECB, the European Environment Agency, the EU Agency for Fundamental Rights (FRA), the Committee of European Auditing Oversight Bodies and the Platform on Sustainable Finance.

Below is a short overview of the ECB, EBA, ESMA and EIOPA opinions — all of which shed light on the sustainability information that financial markets need, and the expectations placed on companies, banks and insurers.

You can download a more comprehensive summary here: Summary of ECB, EBA, ESMA and EIOPA opinions on simplified ESRS 05-03-2026

🔹 Digitisation and usability

ESMA emphasises that effective digital tagging is essential for the usability of sustainability information. Users must be able to identify and retrieve key data efficiently.

🔹 Concerns about cumulative reliefs

All authorities highlight that the accumulation of relief measures risks undermining the CSRD’s objective: creating a reliable, standardised data ecosystem that enables benchmarking, risk differentiation and comparability.

🔹 Permanent reliefs and distorted incentives

They warn that several permanent reliefs could create incentives for undertakings to omit relevant information or delay efforts to improve methodologies and data access. This would weaken the integrity and comparability of disclosures — and increase greenwashing risks.

🔹 Competitiveness and alignment with ISSB

In many areas, the new ESRS reliefs go beyond those in the IFRS ISSB standards, with potential negative consequences for EU companies’ competitiveness and access to global financial markets.

🔹 Reliefs must remain exceptional

The ECB recognises that companies may need initial flexibility while building data systems and estimation methods. But it stresses that reliefs must remain exceptional, not become the norm.

🔹 Progressive capability‑building

For the EBA, once impacts, risks and opportunities (IROs) are identified, undertakings should progressively equip themselves to provide the required ESRS information.

🔹 Avoiding long‑term data gaps

All authorities agree: it is essential to avoid indefinite data gaps and to maintain incentives for companies to start collecting data and improving coverage and quality.

🔹 Assurance implications

ESMA notes that permanent reliefs will require additional judgement from assurance providers and more documentation from preparers — potentially increasing the reporting burden.

👥 FRA’s perspective

In addition, the EU Agency for Fundamental Rights (FRA) issued an opinion focused on safeguards for people adversely affected by corporate activities. FRA warns that several changes may make severe or systemic human rights impacts less visible — especially those occurring deep in value chains or affecting marginalised groups.

FRA’s full opinion is particularly relevant for HR, sustainability and compliance professionals: https://fra.europa.eu/en/news/2026/fra-issues-legal-opinion-proposed-simplified-european-sustainability-reporting-standards

Link to the Omnibus I directive: Directive – EU – 2026/470 – EN – EUR-Lex