Eurogas Position Paper: the Revised European Sustainability Reporting Standards (ESRS)

Full Eurogas position here.

Eurogas recognises the efforts undertaken by EFRAG to simplify the European Sustainability Reporting Standards (ESRS). Transparency, comparability, and useful sustainability information remain essential for the energy transition.

However, based on experience from the first reporting cycle and an assessment of EFRAG’s technical advice to the European Commission, Eurogas considers that the proposed revisions do not yet deliver genuine and effective simplification. While headline reductions in data points are welcome, the underlying reporting effort, data collection burden, and audit complexity remain largely unchanged for many undertakings. In some cases, the revisions risk increasing complexity and an increasing reporting demand, particularly through the introduction of new concepts and additional mandatory disclosures. In addition, we are concerned that the increased complexity and uncertainty introduced by the proposed revisions may negatively affect disclosure quality, leading to more generic, compliance-driven reporting.

This paper outlines our key observations and recommendations and highlights the need for an ESRS framework that ensures a proportionate and principle-based approach to sustainability reporting. It contains:

1. General Assessment of the Revised ESRS
2. Structural Changes and Elimination of Sub-Sub-Topics
3. Implications of Materiality Assessment for Aggregation and Disaggregation
4. Anticipated Financial Effects (AFE)
5. Disclosure of fines, penalties, and compensation related to discrimination and human rights incidents (ESRS S1-16 §42; AR36)
   1. Scope of reportable cases
   2. Severity and relevance of incidents
   3. Implications for assurance and auditability
6. Introduction of new data points and reclassification of voluntary disclosures
7. Social Standards (ESRS S1)
   1. Workforce Composition and Geographic Disaggregation
   2. Financial Resources for Key Actions (ESRS 2 §38)
   3. Remuneration, Pay Gap, and Related Metrics
8.  Environmental Standards (E1-E5)
   1. Pollution (E2)
   2. Water, Biodiversity, and Resource Use (E3-E5)
9.  Interoperability and Application

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