Eurogas Position: Revised European Sustainability Reporting Standards (ESRS)

Full Eurogas position here.

Eurogas welcomes the efforts by EFRAG and the European Commission to simplify the ESRS. The revised standards are overall clearer and better structured, with some improvements.

In particular, Eurogas supports:

• The introduction of the concept of “reasonable and supportable information that is available without undue cost or effort”,
• The explicit recognition of “undue cost”
• A stronger emphasis on decision-useful information.

These are positive steps towards practical implementation and more effective audit discussions.

However, despite these improvements, the overall reporting burden for in-scope companies remains largely unchanged. Simplifications are limited in practice, and significant challenges persist. Further adjustments are required to ensure proportionality, clarity, and operational feasibility.

Eurogas underlines that it provided numerous specific recommendations in its paper addressing the EFRAG proposal [Eurogas Position on EFRAG Revised ESRS], and aims with this document to highlight the issues of highest priority in the Commission proposal.

1. Reporting boundaries
2. Anticipated Financial Effects (AFE)
3. Fair presentation principle
4. Value chain reporting
5. Environmental Standards (E1-E5)
   1. GHG Emissions E1-8 (Scope 1, 2 and 3)
   2. GHG Emissions and acceptance of Mass Balance (Scope 1, 2, 3)
   3. GHG Emissions from purchased cloud computing and data centre services (Scope 3)
6. Social standards
   1. Workforce reporting (ESRS S1-5 & S1-7)
   2. Human rights and Work-related incidents (ESRS S1-16)
   3. Pay Gap Disclosures
   4. Disclosure of fines, penalties and compensation (human rights & discrimination)

Download full PDF below.